Privacy Policy

Bristol Bay
Status: 20 Oct 2019  

 

 

Short Version

At Bristol Bay Insurance, we take privacy and the protection of your Personal Data seriously.

Personal Data means information that can directly or indirectly identify you or other individuals (“Personal Data”). This typically includes information such as your surname, name, name suffix, date of birth, address, email address, telephone number, date of purchase and financial details provided by you in connection with your purchase. Personal Data can also include other information such as your IP address and your shopping habits.

The categories of Personal Data that we process depends on how you use our services. We use your Personal Data to provide our website services in alignment with your preferences, to deal with your requests, to contact you regarding tailored products and services which may be of interest to you, or to carry out relevant administrative services. All Personal Data is processed in accordance with applicable data protection laws.

We do not disclose your Personal Data to any third party except to our affiliates and to data processors that assist us with providing our services. With your consent we use cookies for marketing, performance and statistical purposes.

As our valid customer, we also offer you various choices to control how your Personal Data is used.

If you would like to receive more information about the processing of your Personal Data by us and on the cookies that we use, please see the extended version of this Privacy Policy below, as well as our Cookie Policy.

Extended version

1   Our Privacy Principles

We take privacy seriously. Here are our 6 privacy promises to you:

  1. We will respond to any questions on processing of your Personal Data without undue delay.
  2. We will ensure that your Personal Data is used in line with applicable data protection laws.
  3. We will be transparent with you about how we use your Personal Data. This includes informing you about what information we collect, what we do with it, with whom we share it and whom you should contact if you have any concerns.
  4. We will provide you simple options to say ‘STOP’ when you are no longer happy with our marketing communications.
  5. We will protect online and offline data in a similar manner.
  6. We will take reasonable steps to make sure no unauthorized person accesses your Personal Data.

2   Our Privacy Policy

We are committed to safeguarding your privacy and ensuring that your Personal Data is protected. This Privacy Policy explains the types of Personal Data we collect and how we process and protect that data.

This Privacy Policy applies to Personal Data processed by us in connection with the services and products we offer to you, including through the website www.upverter.com (“Service(s)”). This includes Personal Data collected offline through our regional sales centers and Value Added Resellers (VARs) worldwide or online through this website, applications and branded pages on third party platforms and applications accessed or used through such websites or third party platforms (“Sites”).

This Privacy Policy also applies to our targeted content, including online offers and advertisements for products and services, which we (or a service provider acting on our behalf) may send to you on third party websites, platforms and applications (“Third Party Sites”) based on your use of the internet. These Third-Party Sites may have their own privacy policies and terms and conditions. We encourage you to read them before using those Third-Party Sites.

2.1   Who is Responsible for what happens with your data?

Bristol Bay Insurance LLC (“Bristol Bay Insurance” or “we”; “our”; “us”) is responsible for processing of your Personal Data in relation to the Services. You can contact us via mail at Bristol Bay Insurance LLC, 4225 Executive Square, Suite 700 La Jolla, CA 92037, by phone at +1-858-864-1501, or by email at data.compliance@Bristol Bay Insurance.com if you have any questions.

2.2   Who Is Bristol Bay Insurance’s Data Protection Officer?

The Data Protection Officer of Bristol Bay Insurance is currently Mr. Robert Jeffares. You can contact the Data Protection Officer at data.compliance@Bristol Bay Insurance.com.

​2.3   When Do We Ask For Your Consent?​

By using our Services and our Sites, you acknowledge that we are processing your Personal Data in accordance with this Privacy Policy. If you do not wish that we process your Personal Data in this way, please do not use our Service or Sites or otherwise provide our Sites with your Personal Data.

We process your Personal Data to provide you the Services and the Site. In certain instances, we only process your Personal Data if you have consented, for example in certain cases where we process your Personal Data for marketing purposes, use cookies or process your sensitive Personal Data. Where we process your Personal Data on the basis of your consent, we will ask for your consent explicitly but, in some cases and only where permitted by applicable law, we may infer in a transparent manner consent from your actions. We may also ask you to provide additional consent if we need to use your Personal Data for purposes not covered by this Privacy Policy or before sharing your Personal Data with group companies or relevant subsidiaries of Bristol Bay Insurance for the purposes of marketing.

2.4   What Happens If Our Customer Is A Child?

Our Services and Sites are intended for adults, but there could be instances where some customers under the age of 18 decide to view or purchase Services on our Sites. Our rule is that if we know a customer is under the age of 18, we will not use such customer’s Personal Data for marketing purposes unless parental consent is provided to us in writing. We will not sell any Services to customers under the age of 18.

To provide parental consent, please write to the Bristol Bay Insurance contact details as listed in Section 2.1. Note however that access to certain parts of our Sites and/or Services may be limited to users over a certain age. We may use your Personal Data to carry out age verification checks and enforce any such age restrictions.

2.5   For which purposes do we process your Personal Data?

We collect your Personal Data directly when you provide us with Personal Data when you visit our Sites, purchase Services, subscribe to our newsletter, receive information or mailings, use our applications, complete a survey, and/or make a comment or enquiry or contact our customer services. We may also receive Personal Data about you from other sources, including information from commercially available sources, such as public databases and data aggregators, and information from third parties.

In more detail, we process the following categories of Personal Data for the following purposes:

2.5.1   Surfing on our Sites – with or without Cookies
2.5.1.1   Which Personal Data do we collect about you?

For this purpose (Surfing on our website) we process the following Personal Data: Information about the type of browser you use, details of the web pages you have viewed, your IP and device address, your Cookie ID, hyperlinks that you have clicked, your user name, profile picture, gender, networks, the websites you visited before arriving at our relevant Sites and information collected by cookies or similar tracking devices and any other information you choose to share when using Third Party Sites, e.g. when visiting Bristol Bay Insurance’s sites on social media networks, such as Facebook, Instagram, Twitter or Bristol Bay Insurance’s YouTube channel). Our Sites involve simple links to social media networks; depending on the technology used by the social media it may be the case that Bristol Bay Insurance will transmit Personal Data to the provider of the relevant social media network when you click on such link.

2.5.1.2   What is the purpose of processing your Personal Data?

We (and third-party service providers acting on our behalf or on their own behalf) use cookies and similar technologies to process data about you when you visit our relevant Sites. Cookies are files that store information on your computer hard drive or browser that mean that we can recognise that you have visited us before. We use cookies and similar technologies (like pixels, fingerprints and other tools) to improve our products and your experience on our Sites by evaluating the use of our Sites, products and services and understand your browsing and shopping habits, analysing the effectiveness of our advertisements, personalising your website experience as well as evaluating statistics on website activity, evaluating (anonymously and in the aggregate) statistics on website activity, such as what time you visited it, whether you’ve visited it before and what site referred you to it, reviewing the Services that you have searched online and ended up purchasing them, making our Sites easier to use and to better tailor our Sites and our Services to your interests and needs, identifying that you have visited our Sites but did not purchase a Service, collecting information about your device and linking this to your Personal Data so as to ensure that our Sites present the best web experience for you and supplementing the Personal Data that you provide to us with other information that we hold or that we may receive from commercially available sources, such as public databases and data aggregators, and third parties.

2.5.1.3   How long do we store your Personal Data?

Whether and for how long cookies remain stored on a Device mainly depends on whether the cookie Created is a Persistent Cookie or a Session Cookie. “Session Cookies” are cookies that remain stored on your Device only until you close the browser. By contrast, “Persistent Cookies” will remain stored on your Device until they expire or are deleted by you (e.g. by deleting your browsing history or by your targeted deletion of the cookies via your browser settings). For the duration of storage of the particular cookies, please see the Cookie Table below.

2.5.1.4   What is the legal basis for processing your Personal Data?

Your Consent is the legal basis for processing your Personal Data when surfing on our Sites. You can customize your browser’s cookie settings to reflect your comfort level with cookie security.

2.5.2   Contact
2.5.2.1   Which Personal Data do we collect about you?

For this purpose (Contact) we process the following Personal Data: Surname, name, company email address, telephone or mobile number, passwords, company, country, your currently used PCB layout tool, the reason for requesting Bristol Bay InsuranceLive access, posts and other content you submit to our Sites, other Personal Data you voluntarily provide to us, information on the handling of your request, queries from us and further information submitted with your request. Please, however, refrain from sending us information on your health or other sensitive data in unencrypted emails.

2.5.2.2   What is the Purpose of processing your Personal Data?

We process your Personal Data whenever you contact us and respond to your enquiries and comments. We process your Personal Data that you enter when you subscribe for a Bristol Bay InsuranceLive account or when you subsequently update or amend data in your Bristol Bay InsuranceLive account. We process Personal Data to provide you with our Services that you request from us, including responding to your queries or comments. We look at the Services you buy at our Sites and that you have viewed on our Sites.

2.5.2.3   How long do we store your Personal Data?

We will store your Personal Data only until the aforementioned purposes for which we have collected or received your Personal Data are fulfilled and once our statutory obligations to preserve records have expired.

2.5.2.4   What is the legal basis for processing your Personal Data?

Applicable data protection legislation allows Bristol Bay Insurance to process your Personal Data for the purpose of performance of a contract with you (i.e. fulfil your contact request).

If you provide to us Personal Data that is considered sensitive (e.g. information on your health or ethnic origin), your consent will be the legal basis for processing your Personal Data.

2.5.3   Suggestion of our products and services which may be of interest for you; marketing communication
2.5.3.1   Which Personal Data do we collect about you?

For this purpose (suggestion of our products and services which may be of interest for you ) we process the following Personal Data: Surname, name, company email address, telephone or mobile number, passwords, company, country, your currently used PCB layout tool, the reason for requesting Bristol Bay InsuranceLive access, order history/wishlist (including purchases you make on our Sites or offline), payment history, Services you view on our Sites, favourite store, actions you take on our website or when viewing our emails and your shopping habits and preferences.

2.5.3.2   What is the purpose of processing your Personal Data?

We process your Personal Data to suggest tailored products or services that we think may be of interest to you. We may do this by sending you – via post, email, newsletter, SMS, push notifications or phone – details of products, services, special offers, promotions and other information. We also contact you to offer the opportunity to take part in customer research surveys. You may also receive in-store promotions (such as special coupons) from us when you have a Bristol Bay InsuranceLive account with us.

2.5.3.3   How long do we store your Personal Data?

We will store your Personal Data only until the aforementioned purposes for which we have collected or received your Personal Data are fulfilled and once our statutory obligations to preserve records have expired.

2.5.3.4   What is the legal basis for processing your Personal Data?

If you are a subscriber of our newsletter, your express consent in receiving marketing communications shall be the legal basis for processing.

If you are a shopper who has checked out as a guest on our Sites, Bristol Bay Insurance’s legitimate interests in marketing products you may be interested in shall serve as the legal basis for processing. This shall only apply in relation to Bristol Bay Insurance’s own products and services, i.e. not to products and services of relevant third parties.

You can opt out of receiving such marketing communications at any time by clicking the ‘unsubscribe’ link at the bottom of the communications we send you.

2.5.4   Purchase of Services
2.5.4.1   Which Personal Data do we collect about you?

For this purpose, we process the following Personal Data: Surname, name, postal address, company, country, company email address, telephone or mobile number, passwords, payment history, payment information (i.e. bank or credit card details), order history/wishlist, information on the handling of your request and other Personal Data you voluntarily provide to us.

2.5.4.2   What is the Purpose of processing your Personal Data?

We process your Personal Data to process your online and / or offline purchase and deliver the relevant Service(s) to you as ordered. Your payment related Personal Data may be transferred to payment providers to process your payments.

2.5.4.3   How long do we store your Personal Data?

We will store your Personal Data only until the aforementioned purposes for which we have collected or received your Personal Data are fulfilled and once our statutory obligations to preserve records have expired.

2.5.4.4   What is the legal basis for processing your Personal Data?

Applicable data protection legislation allows Bristol Bay Insurance to process your Personal Data for the purpose of performance of a contract with you (i.e. your purchase of Services).

If you provide to us Personal Data that is considered sensitive (e.g. information on your health or ethnic origin), your consent will be the legal basis for processing your Personal Data.

2.6   Who is receiving your Personal Data?

2.6.1   Our service providers (processors)

We may share your Personal Data with the following data processors (i.e. service providers):

  • relevant companies of Bristol Bay Insurance Group and trusted third parties which directly support our promotional activities, Site administration and your Bristol Bay InsuranceLive account;
  • trusted third parties to help us process and analyse your Personal Data, to give us insights about you that we can use to improve our advertising, products and services, and to track the effectiveness of a particular promotion or campaign;
  • if you purchase Services from us, trusted third parties to allow delivery of the Services you have ordered.

Unless you provided consent, each trusted third party is not authorised by us to use your Personal Data in any other way. Each trusted third party will be required by us to implement adequate technical and organizational measures to protect your Personal Data.

2.6.2   Other recipients (controllers)

We may share your Personal Data with the following controllers (i.e. third parties that process your Personal Data for their own purposes):

  • social media platforms (e.g. Facebook, Instagram) so that they can help us deliver our advertisements directly to your social media page or mailbox;
  • law enforcement or other agencies if we are required to do so by law, or by a warrant, subpoena or court order to disclose your Personal Data.

2.6.3   Sharing your Site usage information

We may with your consent share site usage information with trusted third parties (e.g. advertisers, advertising agencies, advertising networks, data exchanges, etc.) in order to offer you tailored content, including more relevant advertising for products and services which may be of interest to you. These trusted third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to help us deliver customized content and advertising to you when you visit our relevant Sites or third-party sites.

2.7   To which countries do we transfer your Personal Data?

Many of the recipients of your Personal Data are based in the European Union / the European Economic Area. However, we may need to transfer your Personal Data to a location outside of the European Economic Area, including to countries that do not offer the same level of protection with respect to Personal Data as required in the European Economic Area and where there is no adequacy decision by the European Commission. If your Personal Data should be transferred to such country, we have ensured that an adequate level of data protection is achieved by a recognized legal mechanism, e.g. by means of the EU-U.S. Privacy Shield certification, so-called Standard Contractual Clauses, as published by the European Commission or Binding Corporate Rules.

2.8   How long do we process your Personal Data?

We will store your Personal Data only until the aforementioned purposes for which we have collected or received your Personal Data have been fulfilled and once our statutory obligations to retain records have expired.

2.9   What Are Your Rights?

You have the right to request from us

  • Confirmation as to whether or not we process Personal Data from you and, where that is the case, access to your Personal Data;
  • Rectification of inaccurate Personal Data;
  • Erasure of Personal Data;
  • Restriction of processing of Personal Data; and
  • To receive the Personal Data which you have provided to us and to have transmitted those Personal Data to another data controller without hindrance.

2.10   Can You Withdraw Your Consent To The Processing Of Personal Data?

If your consent is the legal basis for the processing of your Personal Data, you can withdraw your consent at any time. This will not affect the lawfulness of the processing based on your consent before the withdrawal. You can withdraw your consent by sending us an email, or by calling us under the phone number listed in Section 2.1. 

2.11   Can You Complain With The Data Protection Authorities?

If you think that the processing of Personal Data by us violates applicable data protection laws, you can lodge a complaint with the competent supervisory authority.

2.12   Do You Have To Provide Your Personal Data To Order On The Sites?

You are not legally required to provide the Personal Data. However, if you do not want to provide your Personal Data, you may not purchase Services or subscribe for a Bristol Bay Insurance Live account.

In order to purchase Services on our Sites or register as a Bristol Bay Insurance Live account holder, you must provide the Personal Data as listed in Section 2.5.4. If you purchase Services that may give an indication about your sensitive Personal Data (e.g. health data), we can only process this order if you consent that we process such data.

If you do not provide the relevant Personal Data or if you reject cookies or do not provide your consent in context of other services than purchasing Services or opening a Bristol Bay InsuranceLive account, you may not receive such services at all or without interruption.

2.13   How Do We Protect Your Personal Data?

We maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your Personal Data. Our security measures are being improved continuously as new technology develops. The processing and transmission of data through our Sites is encrypted by Secure Sockets Layer protocol (“SSL”), which is an encrypting technology to ensure the highest possible security for the transmission of your data, including Personal Data, between your web browser and our internet system. The URL of a website with SSL connection to your browser starts with “https://”. Most browsers indicate SSL-encrypted websites by displaying an icon that depicts a closed padlock. This icon might be located in the address bar or the bottom status bar. If you have turned off your status bar, this icon may not be visible, even on websites that use SSL.

Our Sites may contain hyperlinks to other websites provided by third parties. We do not control these third-party websites or any of the content contained on those websites. Once you have left our relevant Sites, we cannot be responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the relevant privacy policy for the website you visit.

2.14   Can we change our Privacy Policy?

We may change this Privacy Policy from time to time by posting the updated version of the privacy policy here. To the extent processing of your Personal Data be based on your consent, we will not change the scope of such processing, unless you have given additional consent to the changed scope of such processing. We encourage you to visit this area frequently to stay informed.

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