Privacy Policy

Last Updated: September 15th 2020

BigSpring, Inc. and its affiliates (“BigSpring”) values your support and is committed to protecting your privacy. This statement (the “Privacy Policy”) sets forth our policies and practices for handling your information on the BigSpring App and any other website or online service that we operate and that links to this Privacy Policy (the “Services”).

1. COLLECTION OF INFORMATION

We may collect the following kinds of information when you use the Services:

Information you provide directly to us. For certain activities, such as when you register, subscribe to our alerts, or contact us directly, we ask you to provide some or all of the following types of information:
* Contact information, such as full name, email address, mobile phone number, and address;
* Username and password or other authenticating information;
* Payment information, such as credit card number, expiration date, and credit card security code, where needed to complete a transaction;
* Course interaction information, including which courses you took, your progress on the courses, any evaluation results, and any other interactions with our courses or other Services;
* Any content you make available on the Service, including messages, photos, videos, text and other works;
* Consistent with your mobile device or app permissions, we may collect geolocation information (including geolocation information derived from your GPS, WiFi, and Bluetooth signals, IP address, and other device information), contacts from your mobile address book, and appointments from your calendar; and
* Correspondence you send to us.

Information provided about you by your employer. If you are accessing our Services through your employer, potential employer, or business partner, they will provide us some or all of the following types of information so that we can register you to our Services:
* Contact information, such as full name, email address, and mobile phone number; and
* Verification information, such as an employee ID.

Information we collect automatically. We collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, device and advertising identifiers, browser type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, information about the links you click and pages you view within the Services, and other standard server log information. We use this information to maintain and improve security, to deliver updates and to better understand how users use our Services so that we can continue to develop the services we provide.

We may use cookies, pixel tags, Local Storage Objects, and similar technologies to automatically collect this information. Cookies are small bits of information that are stored by your computer’s web browser. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

You may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you.

If required by applicable law, we will specifically request your consent to use cookies and similar technologies. Otherwise, by using the Services, you consent to our use of cookies and similar technologies for the purposes described above. For more information about our use of cookies and similar technologies, please see the “Advertising, Cookies, and Similar Technologies” section below.

2. USE OF INFORMATION

We generally use the information we collect online:
* to provide you with our Services;
* where applicable, to provide your employer or business partner with information regarding your use of the Services in accordance with our agreement with your employer or business partner;
* to provide customer support, respond to your questions or requests for information and communicate with you about the Services;
* to send you promotional materials from us or on behalf of our affiliates and trusted third-party partners, consistent with applicable law;
* to analyze the use of the Services and user data to understand and improve the Services;
* to comply with local laws and in connection with legal proceedings;
* for our own administrative and quality assurance purposes;
* for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

In accordance with applicable law, our legal grounds for processing your personal information are that the processing is:
* necessary for our legitimate interest (that is to operate, improve and develop the Services, ensure its security and respond to your queries);
* necessary in order to comply with our legal obligations; or
* carried out with your consent or at your direction, to provide you with the information and services that you request, which you will be free to revoke, although in that event it may be necessary to retain some information to comply with our legal obligations or protect our rights and interests. To withdraw your consent, please make a request in writing to the contact details set out below.

If you do not provide certain information to us, we may, in some circumstances, be unable to comply with our obligations or provide you with the services that you request. We will tell you about the implications of not providing certain information where required by law.

3. DATA SHARING

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
* Authorized third-party vendors and service providers. We share your information with third-party vendors and service-providers that help us with specialized services, including billing, payment processing, customer service, email deployment, business analytics, marketing, advertising, performance monitoring, hosting, and data processing.
* Your employer or business partner. Where applicable, we share your information with your employer, potential employer, or business partner.
* Corporate affiliates. We may share your information with our corporate affiliates, including BigSpring Private Limited.
* Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
* Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of BigSpring, our affiliates, users, or the public.
* With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

4. SECURITY AND DATA STORAGE

We use reasonable security practices and procedures as required under applicable law to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

We will keep your personal information for a reasonable period of time that enables us to communicate with you, provide you with any services you request, maintain business records for audit purposes or to meet recordkeeping requirements under the law, defend or bring any legal claims and deal with any queries or complaints you may have.

5. YOUR RIGHTS

If you later decide that you do not want your personal information used for the purposes described in this Privacy Policy, you may contact us at our mailing address below to request removal of your personal information from our database. You may also contact us to correct or update any personal information you have provided us. You may also “opt-out” of receiving e-mails and other communications from us by using the unsubscribe feature included in the e-mails we send.

In accordance with applicable law, you may have the right to object to or request restriction of processing of your personal information, and the right to request access, rectification, erasure and portability of your personal information. Where BigSpring is using your information on the basis of your consent, you may have the right to withdraw this consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal. Requests should be submitted in writing to the address listed below in the “Contact Information” section. You may also have the right to lodge a complaint with your data protection authority in accordance with applicable law.

6. ADVERTISING, COOKIES, AND SIMILAR TECHNOLOGIES

When you use our Services, we and our third party advertising partners use cookies, pixel tags, local storage, and other similar technologies (collectively, “cookies”) to collect information from your browser or device. The following types of cookies are used on our Services:
* Essential cookies: These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Without these cookies, certain services cannot be provided. These cookies also help keep our Services safe and secure.
* Preference cookies: These cookies store information such as your preferred country and language selection, login data, and website preferences. Without these cookies, our Services may not be able to remember certain choices you’ve previously made (such as a saved country or language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
* Performance cookies: These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
* Content/advertising cookies: These cookies gather information about your use of our Services so we may improve your experience and provide you with more relevant content and advertising on our Services and elsewhere online and across your devices. They are also used to gather feedback on customer satisfaction through surveys. They remember that you’ve visited our Services and help us understand usage of our Services. Some of these cookies are from third parties that collect information about your use of our Services in order to provide advertising (on our Services and elsewhere, across your different devices) based on your online activities (so-called “interest-based advertising”) on our Services and elsewhere online, across your different devices. We do not control the privacy practices of these third parties, and their practices are not covered by this Privacy Policy. Some of these companies are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here. For additional information on how Google processes your personal information and what choices you may have, visit their site here.

Do-Not-Track Signals and Similar Mechanisms. Some web browsers transmit "do-not-track" signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

7. INTERNATIONAL DATA TRANSFERS

BigSpring operates as a global business, and the information you provide will be accessible to our collaborators and service providers in other countries in which BigSpring operates. BigSpring operates globally, including in the United States, Singapore, and India. Your personal information may be transferred across international borders, and the laws of other jurisdictions may not provide the same level of data protection as the laws in your country. We take reasonable steps to ensure that international data transfers are carried out in accordance with applicable law, and that recipients implement the same level of data protection as required in your home country.

* For individuals resident in the EU only: Your information will be transferred to countries outside your own, such as the U.S. and Singapore, where privacy protections under law may be lower than in your own country. BigSpring implements measures such as Standard Contractual Clauses approved by the European Commission to ensure that any transferred personal information remains protected and secure. A copy of these clauses can be obtained by contacting us at the address listed below in the “Contact Information” section.

8. CHANGES TO THE PRIVACY POLICY

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy. We recommend that you review the Privacy Policy each time you visit the Services to stay informed of our privacy practices.

9. CONTACT INFORMATION

BigSpring, Inc. is the controller of your personal information. If you have any questions about this Privacy Policy or our practices, please contact us by email at: dataprivacy@bigspring.io.