Last Updated: September 18, 2018
1. Information We Collect
1.1 Personal Information. The term “Personal Information” as used herein means information relating to a living individual who is or can be identified from that information or from that information in conjunction with other information that is or comes into our possession.
1.2 Account & Billing Information. If you create an account with us, you will be required to provide us with certain information, including, but not limited to, your name, email address, username and account password. If you elect to purchase Services for which fees are applicable, you will be asked to provide valid and up-to-date credit card information or other payment information. We also collect information if you contact us for support or help, or otherwise communicate with us.
1.3 Information Collected From Your Use of the Services. When you use the Services, we automatically collect certain information, which may include Personal Information, regarding your access to and use of the Services. This information may include, but is not limited to, your IP address, browser type, device type, language, referring website URLs, log files, pages on the website that you visit, and links you click on (collectively, “Usage Information”). We also collect information, including Personal Information, you choose to provide through your use of the Services (for example, if you provide comments to an article or submissions to a forum) (“User Content,” as further defined in the Terms of Service). If you use our Services on a mobile device, you may choose to provide us with location data. We may provide you with the ability to link your account to a third-party website or service. If you link an account you have with a third-party website or service to your account with us, we will obtain information, including any Personal Information that you have provided to the third-party website or service, to the extent allowed by your settings with the third-party website or service and as authorized by you.
1.5. Information From Third Parties. We may receive information about you and your activities on other sites or services from third parties we work with, including affiliates and advertisers.
2. Use of Information We Collect
2.1 Account Creation & Billing. We use information you submit to us at the time of account creation, including Personal Information, and any updated information you subsequently submit, such as a new email address, to create and maintain your account. We may use Personal Information and other payment information you provide to us in order to charge you for Services for which fees are applicable.
2.2 Operation and Improvement of our Services. We use your information, including Personal Information, to operate our business provide the Services to you, personalize the Services we provide to you, improve our Services, and develop new services. We may use your information, including Personal Information, to send you news and updates about our Services, newsletters, alerts, and marketing materials. You may choose to stop receiving newsletters and marketing materials by following the unsubscribe instructions included in the materials or contacting us at terms@playBesst.com. We may use your information, including Personal Information, to verify your identity, for fraud prevention, to enforce the Besst Terms of Service and to protect the integrity of the Services. We may use your information to display advertisements to you.
2.3 Customer Service and Technical Support. We may contact you using the information you provide, including Personal Information, in order to respond to inquiries you send to us, to communicate with you regarding our Services and the services of our partners, and to market our Services, or those of our partners, to you. We may send you emails advertising or promoting our Services. If you do not wish to receive such emails, you can choose to opt-out of receipt using the unsubscribe link within each email or contacting us at firstname.lastname@example.org. We may also use your information to provide technical assistance.
2.4 Aggregate Data. We may monitor use of the Services by all of our users and use the data gathered in an aggregated and anonymous manner for any legal or research purpose. Any such use of aggregate and anonymous data will not include your Personal Information.
3. Information Sharing and Disclosure
3.1 Upon Consent. We may share your information, including Personal Information, with third parties (e.g., Facebook or Twitter) if you provide us with authorization to do so or if necessary to provide you with Services you’ve requested. Some features of our Services may allow you to elect to share information publicly (such as through commenting on articles) or with specific-third parties (through messaging), in which case we would make such information available in accordance with the options you elect.
3.2 Service Providers. We may share your information, including Personal Information, with third- party service providers who assist us in providing our Services and operating our business. This may include payment processors, advertisers, analytical services and customer support providers. If we share your Personal Information with third-party service providers, we require those service providers to maintain the confidentiality of the Personal Information we provide to them, and to not use the Personal Information we share with them for purposes other than the services they are providing to us.
3.3 Responses to Legal Process, Subpoenas or Court Orders. We may disclose your information, including Personal Information, as required by law, such as in response to a court order, subpoena, lawful demand by a public authority, or similar legal process.
Besst reserves the right to share your Information to respond to truly authorized information requests of governmental authorities or where required by law. Besst reserves the right to use or disclose personal information provided to Besst in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, or if Besst reasonably believes that use or disclosure is necessary to protect Besst’s rights and/or to comply with a judicial proceeding, court order, or legal process. In exceptionally rare circumstances where national, state, or company security is at issue, Besst reserves the right to share our entire database of visitors and clients with appropriate government authorities.
3.4 To Protect Our Business, Users or Others. We may disclose your information, including Personal Information, if we believe it is necessary to protect the property and/or rights of Besst, you, or a third party, to protect the safety of the public or any person, in the event of a legal dispute, or to prevent or stop activity we believe may pose a risk of being illegal, unethical or in violation of the Besst Terms of Service.
3.5 Business Transfers. We may sell, assign, transfer or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
3.6 Aggregate Data. We may sell or share aggregate and anonymous data with third parties for any legal purpose, including marketing, advertising, or research purposes.
4. Policy Regarding Children. Our Services are not intended for persons under 13 years of age, and we do not knowingly request or collect Personal Information from persons under 13 years of age. If you are a parent or guardian and believe that your child has provided Personal Information to us without your consent, please contact us at email@example.com. If we become aware that a person under 13 years of age has provided us with Personal Information, we will delete such information from our files.
5. Security. We follow generally accepted industry standards to protect the information we collect, maintain and transmit. We have in place commercially reasonable administrative, technical and physical safeguards to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unauthorized form of processing of the Personal Information in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is completely secure. We cannot, and do not, guarantee the security of any information you transmit to us or store on the Services, and you do so at your own risk. We also cannot, and do not, guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Information has been compromised, please contact us at firstname.lastname@example.org.
If we learn of a security breach involving your Personal Information, we will inform you of the occurrence of the breach in accordance with applicable law.
7. Your California Privacy Rights. We do not share your Personal Information with third parties for their direct marketing purposes without your consent.
8. Privacy Shield
8.1 Notice. This section governs our collection, maintenance, and processing of EU and Swiss Personal Data and provides notice regarding our commitment to and compliance with Privacy Shield Principles. The term “Personal Data” means information relating to an identified or identifiable natural person.
8.2 Collection and Use. We collect and use EU and Swiss Personal Data as set forth above in Section 1 and Section 2.
8.3 Third Party Disclosure. We may disclose EU and Swiss Personal Data as set forth above in Section 3.
8.4 Purpose and Limitation. We limit the use and disclosure of EU and Swiss Personal Data as set forth above in Section 2 and Section 3.
8.5 Security. We protect the security of EU and Swiss Personal Data as set forth above in Section 5.
8.6 Onward Transfer. We are responsible for the processing of EU and Swiss Personal Data under the Privacy Shield Framework and for subsequent transfers to third parties acting as an agent on our behalf. We maintain contracts with these third parties restricting their access, use and disclosure of Personal Data in compliance with our Privacy Shield obligations. We comply with the Privacy Shield Principles for all onward transfers of EU and Swiss Personal Data.
8.7 Sensitive Data. We do not disclose sensitive data, which includes information regarding race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health or sex, to third parties, except those third parties acting as an agent to perform tasks on our behalf and with whom we maintain contracts.
8.8 Access and Choice. We are committed to respecting the rights EU and Swiss individuals have to access, amend or delete Personal Data about themselves, and to limit the use and disclosure of their Personal Data. You may contact us at email@example.com to submit requests regarding your Personal Data.
8.9 Recourse; Enforcement; Liability. In compliance with Privacy Shield, we commit to resolve complaints about our collection or use of Personal Data. EU and/or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at terms@playBesst.com. We will respond within 45 days.
We have further committed to refer unresolved Privacy Shield complaints to BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgement of your complaint from us, or if we have not resolved your complaint, please contact or visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information or to file a complaint. The services of BBB EU Privacy Shield are provided at no cost to you.
Finally, as a last resort and in limited circumstances, individuals with unresolved privacy complaints can invoke a binding arbitration option before a Privacy Shield Panel.
8.11 Jurisdiction. With respect to the EU and Swiss Personal Data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory investigation and enforcement powers of the U.S. Federal Trade Commission.