Bobsled Privacy Policy

Last Revised: December 8, 2023

Bobsled, Inc. (“Bobsled”) is committed to protecting the privacy of individuals. This Privacy Notice (“Privacy Notice”) explains how information is collected, used and disclosed by Bobsled, and applies to information collected when you use or access our online or mobile websites (such as WWW.BOBSLED.CO), products and services (collectively, the “Bobsled Platform” or “Services”), or when you attend a Bobsled event, or otherwise interact with us.

We respect the privacy rights of users and recognize the importance of protecting information collected about you. Please read the following carefully to understand how we will collect, use and maintain your personal information, as well as your choices regarding use, access and correction of your personal information.

Changes to This Notice

This Privacy notice may occasionally change. If and when we make changes, notification of material changes will be reflected by updating the revision date at the top of this Privacy Notice. In some cases, we may provide additional notice (such as adding a statement to our homepage or sending you an email notification).

Your use of the Bobsled Platform after the posting of such changes shall constitute your consent to such changes.

Information Collected

Bobsled collects the following types of personal information:

‍Information you provide to us
We collect information you provide directly to us including when you visit one of our websites, register for and/or use Bobsled Services.

For example, we collect information when you request information via a form on our website; participate in a survey, contest, promotion, sweepstakes, activity or event; make a purchase; apply for a job; customer support; or communicate with us via third-party social media sites.

The types of information we may collect directly from you include your name, username, email address, postal address, phone number, employer’s name, job title, transactional information (including services purchased or subscribed to and billing address) as well as any contact or other information you choose to provide.

‍Information we collect automatically
When you visit bobsled.co or use the Bobsled Platform, we may collect information sent to us by your computer, mobile phone, or other access device. The information sent to us includes, but is not limited to, the following: data about the pages you access, computer IP address, device ID or unique identifier, device type, geolocation information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, and standard web log data and other information. We may also collect anonymous information through our use of cookies and web beacons.

How Do We Use Your Data?

Bobsled uses personal information in order to perform the services requested. For example, information provided while filling out a “demo request” form on bobsled.co will be used to contact you about scheduling a product demo.

Specifically, the information may be used in the following ways:

• Provide, operate, maintain and improve the Bobsled Platform
• Enable you to access and use the Bobsled Platform
• Send you technical notices, updates, security alerts, and routine administrative messages
• Provide and deliver the services and features you request, process and complete transactions, and send you related information, including purchase confirmations and invoices
• Respond to your comments, questions, and requests and provide customer service and support
• Communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about Bobsled
• Monitor and analyze trends, usage, and activities in connection with the Bobsled Platform
• Investigate and prevent unauthorized access to the Bobsled Platform
• For other purposes about which we notify you

Bobsled may also use information provided during event registration for marketing purposes. For example, Bobsled may use information you provide in order to further discuss your interest in the Bobsled Platform.

Bobsled may also use your information as may be required to meet our legal requirements and enforce our legal terms.

‍We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
  ○ IP address
  ○ Device identifiers
  ○ First and Last name
  ○ Email address
  ○ Cookies and other tracking technologies

• Examples of these legitimate interests include:
  ○ Operation and improvement of our business, products and services
  ○ Marketing of our products and services
  ○ Provision of customer support
  ○ Protection from fraud or security threats
  ○ Compliance with legal obligations
  ○ Completion of corporate transactions
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data?

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Notice or our Terms of Service. These parties may include:

• Payment processors
• Fraud prevention service providers
• Analytics service providers
• Staff augmentation and contract personnel
• Other service providers that help us provide our services.
• Companies that we plan to merge with or are acquired by. (Should such a combination occur, we will require that the new combined entity follow this Privacy Notice with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice.)
• Other third parties with your consent or direction to do so.
  

We may also share Personal Data when we believe it is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and services

We do not sell or rent your personal information to third parties for their marketing purposes.

How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

Customer Testimonials

Bobsled publishes customer testimonials on its website which include information such as name, title, and organization. In all cases, Bobsled seeks and receives prior written consent to the publication of such information.

How We Use Cookies and Similar Technologies

When accessing Bobsled.co or the Bobsled Platform, we may place small data files on your computer or other device. These data files may be cookies, pixel tags, e-tags, “Flash cookies,” web beacons, clear GIFs, JavaScript, or other local storage provided by your browser or associated applications (collectively “Cookies”). Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone, or similar device, when you use that device to visit a Site. We will refer to cookies and similar technologies simply as “Cookies” for the remainder of this Cookie Policy. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit and otherwise use the Services through the internet, to analyze trends, and to learn about our user base.

We may combine non-personally identifiable information collected through cookies with other Personal Information that we have about you, for example, to tell us who you are or whether you have an account. We may also supplement the information we collect from you with information received from third parties in order to enhance our Services.

You can control and/or delete cookies as you wish – for details, see aboutcookies.org. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work. We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Services.

Further information on cookies can be found at http://ec.europa.eu/ipg/basics/legal/cookies/index_en.html

What types of cookies do we use and for which purposes?

We use the following types of Cookies:

Essential Cookies

These are cookies that are required to provide you with features or services that you have requested. For example, Cookies that enable you to log into secure areas of our site. Disabling these Cookies will encumber the Services’ performance and may make certain features and services unavailable.

Functionality Cookies

These Cookies are used to recognize you when you return to our Services. This enables us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

Session Cookies and Persistent Cookies

The types of Cookies described above may be “session Cookies” which are temporary Cookies that are only stored on your device while you are visiting our site or “persistent Cookies” which are Cookies that are stored on your device for a period of time after you leave our site. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent Cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Services, how often you return, how your use of the Services may vary over time, and measure the effectiveness of advertising efforts. Through these Cookies, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience.

Cookie Settings

You can decide whether or not to accept Cookies. One way you can do this is through your internet browser’s settings. To find our more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/.

To explore what Cookie setting are available to you, look in the “preferences” or “options” section of your browser’s menu.

If you have any queries regarding this Cookie Policy please contact us at privacy@bobsled.co.

Protection and Storage

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, the use of third-party service providers. We, and third-party service providers on our behalf, store and process your personal information in the United States and elsewhere in the world. If your information is transferred to other countries, including countries which may not have data protection laws that provide the same level of protection that exists in your country, we will protect the information as described in this Privacy Notice.

The servers on which personal information is stored are kept in a controlled environment with limited access. While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable. In addition, we cannot guarantee that any passively-collected personal information you choose to include in documents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.

Security

While no service is completely secure, Bobsled takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls, and information access authorization controls.

You may access your account information and our service only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.

European Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Bobsled will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Notice, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@bobsled.co. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

What Rights Do You Have Regarding Your Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@bobsled.co. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. Please note that these rights may be subject to additional conditions and exceptions under applicable law.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by contacting us at privacy@bobsled.co.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can correct some of this information directly by contacting us at privacy@bobsled.co.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Bobsled’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data

The Bobsled App is hosted and operated through Bobsled and its service providers in either the EU or the US according to each customer’s chosen configuration but in either case, your Personal Data may be processed in the US. Personal Data is stored by the Bobsled App. If you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Bobsled in the U.S. and will be hosted on U.S. servers, and you authorize Bobsled to transfer, store and/or process your information to and in the U.S. in accordance with the Data Privacy Framework (discussed below).  

Data Privacy Framework(s)

Bobsled complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce.  Bobsled has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of all personal data received from the European Union in reliance on the EU-U.S. DPF. Bobsled has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles, the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles shall govern.  To learn more about the EU-U.S. DPF and the Swiss-US DPF, and to view our certification, please visit https://www.dataprivacyframework.gov/.

The Federal Trade Commission has jurisdiction over Bobsled’s compliance with the EU-U.S. DPF and the Swiss-U.S. DPF. This Privacy Policy describes the types of Personal Data we collect, the purposes for which we collect and use your Personal Data, and the purposes for which we disclose your Personal Data to certain types of third parties in the sections above.  Pursuant to the EU-U.S. DPF and the Swiss-U.S. DPF, EU, and Swiss individuals have the right to obtain our confirmation of whether we maintain Personal Data relating to them in the U.S. Upon request, we will provide EU, and Swiss individuals with access to the Personal Data that we hold about them. EU and Swiss individuals may also correct, amend, or delete the Personal Data we hold about them where it is inaccurate, or has been processed in violation of the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. An EU and Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the U.S. under the EU-U.S. DPF and the Swiss-U.S. DPF, should direct their query to PRIVACY@BOBSLED.CO. If requested to remove data, we will respond within a reasonable timeframe. For more information about rights afforded to EU, and Swiss individuals, please see the “European Union and Swiss Data Subject Rights” section of this Privacy Policy.

In addition, under the EU-U.S. DPF and the Swiss-U.S. DPF, we will provide EU and Swiss individuals with the choice to opt-out from the sharing of their Personal Data with any third parties (other than our agents or those that act on our behalf or under our instruction), or before we use it for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized. Direct all such requests to PRIVACY@BOBSLED.CO.

In addition to any other disclosures described in our Privacy Policy, 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.

Bobsled accountability for Personal Data that it receives in the U.S. under the EU-U.S. DPF and the Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on our behalf is described in the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles. In particular, Bobsled remains liable under the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles if our agents process Personal Data in a manner inconsistent with the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles, unless Bobsled proves that we are not responsible for the event giving rise to the damage.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, Bobsled commits to resolve EU-U.S. DPF Principles and Swiss-U.S. DPF Principles-related complaints about our collection and use of your Personal Data. EU and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the DPF should first contact Bobsled at PRIVACY@BOBSLED.CO.

In compliance with the EU-U.S. DPF and the Swiss-U.S. DPF, Bobsled commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the U.S. If you are an EU or Swiss individual and you do not receive timely acknowledgment of your EU-U.S. DPF Principles or Swiss-U.S. DPF Principles-related complaint from us, or if we have not addressed your EU-U.S. DPF Principles or Swiss-U.S. DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Notwithstanding the foregoing, with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF  and the Swiss-U.S. DPF in the context of the employment relationship, Bobsled commits to cooperate and comply with, respectively, the panel established by the EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner.

If your EU-U.S. DPF and the Swiss-U.S. DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Annex 1 of the Data Privacy Framework Principles, located at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

Correcting and updating your information

Bobsled may retain your information for a period of time consistent with the original purpose of collection (for instance, we may retain your information for during the time in which you have an active Bobsled account), and for a reasonable period of time afterward. We also may retain your information during the period of time needed for Bobsled to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

You may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us through Bobsled’s website or the Bobsled Platform. Direct all such requests to privacy@bobsled.co. Requests to access, change, or delete your information will be addressed within the legally permissible timeframe.

Customer Data

Bobsled’s Customers may electronically submit data or information to the Bobsled Platform for hosting and processing purposes (“Customer Data”). Bobsled will not review, share, distribute, or reference any such Customer Data except as provided in an applicable Master Subscription Agreement, or as may be required by law. Bobsled may access Customer Data only for the purpose of providing the services or preventing or addressing service or technical problems, or as may be required by law.

Minors

Bobsled does not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us at privacy@bobsled.co. If we become aware that a child under 16 has provided us with personal information, we will take steps to immediately delete such information.

What If You Have Questions Regarding Your Personal Data?

If you have any questions about this section or our data practices generally, please contact using the following information:

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