BayBridgeDigital LLC, with registered USA (“BayBridgeDigital”), is committed to protecting the online privacy of the users of the web BayBridgeDoigital.com (the “Website”). As such, this Privacy Policy has been written in order to allow you to understand BayBridgeDigital’s policy regarding your privacy, as well as how your personal information will be handled when using the Website. This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.

In general, any information and data which you provide to BayBridgeDigital over the Website, or which is otherwise gathered via the Website by BayBridgeDigital, in the context of the use of BayBridgeDigital’s services (“Services”) as better defined in the Section 3 below, will be processed by BayBridgeDigital in a lawful, fair and transparent manner. To this end, and as further described below, BayBridgeDigital takes into consideration internationally recognized principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimization, data quality and confidentiality.

CONTENTS

  1. Data controller and Data Protection Officer
  2. Personal Data processed
  • 2.1 Name, contact details and other Personal Data
  • 2.2 Job applications
  • 2.3 Special categories of Personal Data
  • 2.4 Browsing data
  • 2.5 Cookies
  1. Purposes of processing
  2. Grounds for processing and mandatory or discretionary nature of processing
  3. Recipients of Personal Data
  4. Transfer of Personal Data
  5. Retention of Personal Data
  6. Data subjects’ rights
  7. Amendments
  1. Data controller and Data Protection Officer BayBridgeDigital, as identified at the top of this Privacy Policy, is the data controller regarding all personal data processing carried out through the Website. To get in touch with BayBridgeDigital’s Data Protection Officer, please contact: rimpenge@baybridgedigital.com.
  2. Personal Data processed: When you use the Website, BayBridgeDigital will collect and process information regarding you (as an individual) which allows you to be identified either by itself, or together with other information which has been collected. BayBridgeDigital may also be able to collect and process information regarding other persons in this same manner, if you choose to provide it to BayBridgeDigital. This information may be classified as “Personal Data” and can be collected by BayBridgeDigital both when you choose to provide it (e.g., when you subscribe to the newsletter or request information in order to receive BayBridgeDigital’s Insights) or simply by analyzing your behavior on the Website. Personal Data which can be processed by BayBridgeDigital through the Website are as follows:

                           2.1 Name, contact details and other Personal Data: In various sections of the Website – including, in particular, if you decide to create an account on the Website – you will be asked to submit information such as your name, phone / mobile numbers, e-mail address, date of birth, country of residence and address etc. In addition, whenever you participate in surveys and other promotions which may be available on the Website, as well as whenever you communicate with BayBridgeDigital through the contact details provided in the Website or with Customer Service, BayBridgeDigital may collect additional information which you choose to provide.

                          2.2 Job applications: When registering to apply for a position within BayBridgeDigital on the Website https://baybridgedigital.com/careers/  (“Careers”), you will also be asked to provide various types of Personal Data, including professional/employment details (e.g., resume, cover letter, professional qualifications, candidate’s expectations and wished workplace, availability to start, URLs, etc.).The Personal Data that you will provide for that purpose will be processed by BayBridgeDigital pursuant to the Privacy Policy published therein.

                          2.3 Special categories of Personal Data: Certain areas of the Website  include free text fields where you can provide BayBridgeDigital with some information or needs, which you may use to communicate Personal Data.

                          2.4 Browsing data: The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While BayBridgeDigital does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data. This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on. These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website. Save from this last purpose, these data do not persist for more than 7 working days.

                          2.5 Cookies Relevant information on the use of cookies are available in the Cookie Policy here.

  1. Purposes of processing BayBridgeDigital intends to use your Personal Data, collected through the Website, for the following purposes:
  • To verify your identity and assist you, in case you lose or forget your login / password details for any of BayBridgeDigital’s registration services by maintaining a registered user profile, to send you BayBridgeDigital newsletter you subscribed for as a service and which contains only informative material, to send you any information you explicitly requested.
  • For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, SMS, over the phone, banners instant messaging, through an operator, traditional mail, through BayBridgeDigital’s official social media pages, regarding BayBridgeDigital‘s products and services, as well as those of selected third parties (“Marketing”);
  • For future marketing, promotional and publicity purposes, by sending you direct e-mail marketing communication regarding products and services (“Soft Spam”);
  • For compliance with laws which impose upon BayBridgeDigital the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
  • To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”).
  1. Grounds for processing and mandatory / discretionary nature of processing
  • Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give BayBridgeDigital your Personal Data for these purposes; however, if you do not, BayBridgeDigital will not be able to provide any Services to you.
  • Marketing: processing for these purposes is based on your consent. It is not mandatory for you to give consent to BayBridgeDigital for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from BayBridgeDigital). Any consent given may also be withdrawn at a later stage
  • Soft Spam: processing for this purpose is based on the interest of BayBridgeDigital of sending you direct e-mail marketing communication regarding products and services. You can block these communications, and you will suffer no consequence if you do so (aside from not being able to receive further communications from the BayBridgeDigital), by opposing through the link provided at the bottom of all such communications.
  • Profiling: processing for this purpose is based on your consent collected by means of the banner cookie and/or with a specific tickbox. It is not mandatory for you to give consent to BayBridgeDigital for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalization of your user experience regarding the Website). Any consent given may also be withdrawn at a later stage.
  • Compliance: processing for this purpose is necessary for BayBridgeDigital to comply with its legal obligations. When you provide any Personal Data to BayBridgeDigital, BayBridgeDigital must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
  • Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes).
  1. Recipients of Personal DataYour Personal Data may be shared with the following list of persons / entities (“Recipients”):
  • Persons, companies or professional firms providing BayBridgeDigital with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services and which act typically as data processors on behalf of BayBridgeDigital;
  • Entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers);
  • Persons authorized to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
  • Persons authorized by BayBridgeDigital to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of BayBridgeDigital);
  • Other companies within the BayBridgeDigital Group for internal administrative purposes, including the processing of clients’ or employees’ Personal Data; and
  • Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
  1. Transfer of Personal Data: Considering BayBridgeDigital’s worldwide presence and business operations, your Personal Data may be transferred to Recipients located in several different countries. BayBridgeDigital implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand. More information about it are available sending a written request to BayBridgeDigital at the following address: rimpenge@baybridgedigital.com.
  1. Retention of Personal Data Personal Data processed for Service Provision will be kept by BayBridgeDigital for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, BayBridgeDigital may continue to store this Personal Data for a longer period, as may be necessary to protect BayBridgeDigital’s interests related to potential liability related to the provision of the Services. Personal Data processed for Marketing and Profiling will be kept by BayBridgeDigital from the moment you give consent until the moment you withdraw the consent given and renewed at fixed intervals. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by BayBridgeDigital, in particular as may be necessary to protect BayBridgeDigital’s interests related to potential liability related to this processing. Personal Data processed for Soft Spam will be kept until you object to such processing by means of the link provided at the bottom of all such communications.

Personal Data processed for Compliance will be kept by BayBridgeDigital for the period required by the specific legal obligation or by the applicable law.

Personal Data processed for preventing Misuse/Fraud will be kept by BayBridgeDigital for as long as deemed strictly necessary to fulfil the purposes for which it was collected.

  1. Data subjects’ rights Under the Regulation, you, as a data subject, are entitled to exercise the following rights before BayBridgeDigital, at any time:
  • Access your Personal Data being processed by BayBridgeDigital (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
  • Correct or update your Personal Data processed by BayBridgeDigital, where it may be inaccurate or incomplete;
  • Request erasure of your Personal Data being processed by BayBridgeDigital, where you feel that the processing is unnecessary or otherwise unlawful;
  • Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
  • Exercise your right to portability: the right to obtain a copy of your Personal Data provided to BayBridgeDigital, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
  • Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent BayBridgeDigital from processing your Personal Data; or
  • Withdraw your consent to processing (for Marketing and Profiling).Please note that most of the Personal Data you provide to BayBridgeDigital can be changed at any time, including your e-mail preferences, by accessing, where applicable, the user profile you can create on the Website. When requesting for the Services, you may have selected the means of communication through whom you desired the Marketing to be carried out (i.e. fax, phone, SMS, email, mail, social media). You may withdraw the consents for the Marketing through the different means of communication from the user profile, where applicable, by de-selecting the relevant options. You can also withdraw consent for Marketing via e-mail or object to Soft Spam by selecting the appropriate link included at the bottom of every e-mail message received. The same applies to the BayBridgeDigital newsletter you receive as a Service. Aside from the above means, you can always exercise your rights described above by sending a written request to BayBridgeDigital at the following address: rimpenge@baybridgedigital.com.

In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful.

  1. Amendments This Privacy Policy entered into force on 16/03/18. BayBridgeDigital reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. BayBridgeDigital will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. BayBridgeDigital therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how BayBridgeDigital collects and uses Personal Data.