Last Update: May 21st 2018 -- Effective Date: May 25th 2018
This Privacy Notice applies to the following websites:
(1) Bang (collectively, the "Sites", or individually, a "Site").
OVERVIEW
SCTR Services (also referred to herein “SCTR”, “Company”, “us” or “we”) is committed to respecting your privacy and recognizes the need for appropriate protection and management of any personally identifiable information ("Personal Information") you share with us. In order to provide you with the services you may request, including access to the member’s-only area of our sites (collectively "Services"), We collect and use your Personal Information.
To protect your privacy, we have adopted and comply with the following principles:
This Privacy Notice describes the types of information we collect from you or that you may provide when visiting our websites, and our practices for collecting, using, maintaining, protecting, and disclosing that information. As used in this Privacy Notice, “personal information” means information which relates to an individual and which identifies that individual, either directly or indirectly, such as your name or your contact information.
This Privacy Notice applies to information we collect in all of the following ways:
Please read this Privacy Notice carefully to understand our policies and procedures regarding your personal information and how we will treat it. If you do not agree with our policies and procedures, your choice is to stop using our websites.
By using our websites and creating an account, you acknowledge that you have reviewed this Privacy Notice and agree to the terms and conditions described within this Privacy Notice and in our Terms and Condition. If you do not agree with our privacy policies and procedures, please ask us to remove your account and please do not use our websites or services.
ACCEPTANCE OF TERMS
By accessing and using our Sites, you agree that we may use any personal information you have provided or that has been collected for any purpose within the constraints of the law, including technical, administrative, research and development, customer administration, marketing, trading of personal data, age verification, promotion and advertising by this website or authorized third parties. By using this site, you agree that the site may, within the constraints of the law, share, disclose, transfer, rent, license or sell any of the personal information that it has gathered or collected with third parties. All information collected may be shared to comply with applicable law and/or to cooperate with law enforcement agencies and courts/tribunals.If you do not agree with our information practices, please do not access or use our Sites.
As provided below, we reserve the right, at our discretion, to change, add or remove portions of this policy at any time by posting such changes to this page. Such changes will be effective upon posting.
NOTICE
DATA COLLECTED AND ITS USES
Visitors:
If you do not have an account, you are a visitor and we do not collect any personal information about you other than through our use of cookies, which are described below. But if you wish to register in order to make use of our services, you will need to provide certain information.
Registered Users (“Users”)
When you become a User, you provide us with personal information as follows: :
Our Company is the sole owner of the information collected. We will not sell, share, or rent this information to third parties, except as set forth in this Privacy Notice. We will not use any of your Personal Information to send you any promotional materials or advertisements unless you have requested that we do so. If you are a customer, you may receive from us order/cancellation e-mail confirmations that are automatically generated whenever an order/cancellation is placed through us and that confirm your purchase or cancellation with important details about your purchase or cancellation, including but not limited to, product purchased/cancelled, order/cancellation date, username/password and our customer service toll free telephone number that may be used for any inquiries about the purchase/cancellation.
We also occasionally send you content updates and special offers from us or our partners. You can opt out of receiving these at any time, and you can edit your personal information, preferences and subscriptions in your Account Settings.
WHO WE SHARE YOUR DATA WITH (AND WHY)
We only ever share your personal data with other companies if necessary for the operation of our Sites. These other companies are legally required to have the same data security standards we do. Below you can find a complete list of who we might share your data with. Note that we may change our partners in the future, in which case this document will be updated.
| WHY | WHAT | WHO |
| Billing | Credit card, email, first and last name, country, ZIP or post code | If you sign up to one or more of our websites, your credit card or other billing data is processed by one of our payment processors; ECHST.net, Epoch, Segpay, CCBill or Vendo. You can tell which of these companies processes your data from both the page you see when you pay for your subscription, as well as from the billing related emails you receive. We also store billing related data (email, first and last name, country, but not your credit card or other payment information) in our internal systems. |
| Support | | In order to help you with any support requests our customer support team uses tools hosted by Zendesk. We only store your email address in Zendesk if you contact us. In some cases, in order to provide you with the support you require, other data you provide might be stored with Zendesk over the course of your support request. In addition sometimes information needs to be shared with our technical teams so we can investigate or action your requests. Our customer support representatives also use the Google suite to answer Zendesk tickets in a timely manner. |
| Marketing | | We use Sendgrid to process our email campaigns, and we will share your email address with them to send you the emails you requested. |
| Error Tracking | IP address | We use Sentry.io to aggregate errors from our Sites and to fix them adequately. |
| Hosting & Security | All Data | We use Amazon Web Services to host our websites on its infrastructure in the USA. We also use Amazon Web Services to host all data (including yours) in securely encrypted form. On top of that we use Cloudflare to protect both ourselves and you from fraudulent attempts to access the site and your data. |
Except as provided above, we do not currently sell or otherwise make available personally identifiable information about our users to third parties. Nevertheless, we reserve the right to make such information available to third parties in the future in order to enhance and personalize our services, or in the case of bankruptcy, sale of an asset, business or division, a merger or acquisition, or similar change of ownership.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
Our legal basis for collecting and using the Personal Information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect Personal Information from you only where:
" Legitimate interests" means the interests of our company in conducting and managing our business to enable us to give you the best service/products and the best and most secure experience. For example: we have an interest in keeping our network secure. It can also apply to processing that is in your interests as well. For example: we may process your Personal Information to protect you against fraud when transacting on our website. We process Personal Information for certain legitimate business purposes, which include some or all of the following:
When processing your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative) and your rights under the data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). If you have any concerns about the processing, you have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see "Your Rights" section below.
CHOICE
You may choose whether or not to provide Personal Information to us. If you choose not to provide the Personal Information we request, you can still visit most of the Sites, but you will be unable to purchase a product or service online, setup an account with us and/or use any of our other paid Services. If you choose to have a relationship with us, such as a contractual or other business relationship, you will be required to provide Personal Information in connection with such relationship.
From time to time, we may send our users e-mail or other notices regarding new services, promotions, or other information which may be of general interest. Users who no longer wish to receive materials from us may opt-out of receiving these communications by clicking on the “unsubscribe link’ or by contacting us.
ACCOUNTABILITY FOR ONWARD TRANSFER
When we transfer Personal Information to a third party we will ensure that our agreement with the third party provides that such Personal Information may only be processed for limited and specified purposes consistent with the consent you provided and that the third party will provide the same level of protection as the Privacy Shield Principles and will notify us if it determines that it can no longer meet this obligation. In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-US Privacy Shield or Swiss-US Privacy Shield respectively, we are potentially liable.
SECURITY
The Sites are all using SSL 128-bit encryption for any form where you enter any data. All of your data is also stored securely. We use commercially reasonable efforts to protect the information you have provided to us from unauthorized access by using encryption and other security measures. We have adopted and implemented industry standard technology for maintaining the security of all personal information collected by our websites. While we use commercially reasonable physical, managerial and technical safeguards to secure your personal information, the transmission of information via the Internet can never be one
hundred percent secure. As a result, we can assume no liability if information relating to any subscriber is intercepted and/or used by an unintended recipient. We encourage you to contact us if you are interested in learning more about our security measures.
DATA INTEGRITY & PURPOSE LIMITATION
We will take reasonable steps to ensure that all personal information that we collect is accurate, complete, current and reliable for its intended use and purpose which may include those that reasonably serve payment processing, customer relations, compliance and legal considerations, auditing, security and fraud prevention, preserving or defending our legal rights or other reasonable uses in this context.
You may send updates and corrections about your Personal Information to support@bang.com and we will make reasonable efforts to incorporate the changes in your Personal Information that we hold as soon as practicable. We will retain your Personal Information only for as long as it is necessary for purposes as identified above.
ACCESS
You may inquire about your Personal Information being held by the Company by sending an email to support@bang.com or by visiting Your Account Settings . Upon meeting certain security measures, The Company shall provide you with a copy of the Personal Information that it keeps about you. Prior to completing your request, the Company may require that you provide us with certain items as a proof of your identity. We reserve the right to refuse a request where the burden or expense of providing access would be disproportionate to the risks to your privacy or where the rights of persons other than You would be violated.
RECOURSE, ENFORCEMENT & LIABILITY
SCTR complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. SCTR has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/ In compliance with the EU-US Privacy Shield Principles and Swiss-US Privacy Shield Principles, we are committed to investigate and expeditiously resolve complaints about your privacy and our collection or use of your Personal Information. The Company uses the self-assessment method of verification of compliance and is subject to the enforcement authority of the US Federal Trade Commission.
European Union and Swiss individuals with inquiries or complaints regarding this Privacy Notice should first contact us at support@bang.com or via post at SCTR Services, Attn: Chief Privacy Officer, 800 Stewart St, Seattle, WA 98101, USA.
We have further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles and Swiss-US Privacy Shield Principles to JAMS, an independent dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint regarding our compliance with the EU-US Privacy Shield Principles or Swiss-US Privacy Shield Principles or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield to file a complaint.
If you do not receive a timely acknowledgment of your complaint regarding our compliance with the EU-US Privacy Shield Principles or Swiss-US Privacy Shield from JAMS or if your complaint is not satisfactorily addressed through JAMS, EU individuals may complain to the US Department of Commerce through the EU Data Protection Authority in the country in which you reside while Swiss individuals may complain to the US Department of Commerce through the Swiss Federal Data Protection and Information Commissioner in Switzerland.
If you do not receive a timely acknowledgment of your complaint regarding our compliance with the EU-US Privacy Shield Principles or Swiss-US Privacy Shield Principles from the US Department of Commerce or if your complaint is not satisfactorily addressed through the US Department of Commerce, EU individuals may invoke arbitration with the Privacy Shield Panel to determine whether we have violated our obligations under the EU-US Privacy Shield Principles. For more information about the arbitral model, please review Annex 1 available at http://ec.europa.eu/justice/data-protection/files/annexeseu-usprivacyshielden.pdf. Swiss individuals may be able to invoke arbitration in the future with the Swiss Federal Data Protection and Information Commissioner in Switzerland.
YOUR RIGHTS
You have the following data protection rights:
COOKIES
A cookie is a piece of data stored on the user's hard drive containing information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our Sites. Cookies are used for various purposes like tracking your movement through the sites in order to help us to improve your experience, serving you relevant advertising, making sure that we can pay affiliates, keeping you logged in between visits, etc. Please note that some of our business partners may also use cookies on our Sites (for example, advertisers). However, we have no access to or control over these cookies. Every browser offers the option to delete or block these cookies, usually in their settings options.
THIRD PARTIES
Any websites displayed to you by our Websites as Internet search results or linked to Internet search results pages provided to you by our Websites have been developed by third parties over which the Company exercises no control. Such websites may send their own cookies to end users, collect data, or solicit personal information from you. The Company is not responsible for the privacy practices or the content of such websites, including such websites' use of any information collected when you are directed to or click through to such websites. Even though such information might not identify you personally, we strongly encourage you to become familiar with the privacy practices of those websites. If you click on any advertising or special offers on this website you may be directed to a third party website that is outside our control, and in some cases, we might share some data with those websites in order to make things easier for you. In these cases, you are responsible for making sure that these websites keep your data as safe as we do.
DATA RETENTION
Unless you ask to have it deleted, we will store your data indefinitely in order to give you continued access to any content that was present at the time your subscription ended.
LAW ENFORCEMENT
We will cooperate with law enforcement authorities, private-party litigants, and others seeking information about our end users to the extent required by applicable law. We will also notify the appropriate authorities if we suspect that any of our users are engaged in illegal activities, such as obscenity or child pornography.
MINORS UNDER THE AGE OF 18
Our Sites are not intended for children. Our Sites do not target children, nor do we solicit data, or knowingly collect personally identifiable information from them. We encourage parents and legal guardians to spend time online with their children and to participate in the interactive activities offered on the sites their children visit. We encourage you to visit ASACP.org where you can find multiple ways to protect your children and your family.
Member areas of our Sites may contain content considered offensive to some and are inaccessible to individuals under the age of 18 via a standard credit card wall, as advocated by the Communications Decency Act. It is possible that by fraud or deception we may receive information given to us or pertaining to minors under the age of 18. If we are notified of this and it is verified, we will immediately delete the information from our servers. If you want to notify us of our receipt of information by minors, please do so by emailing us at support@bang.com.
CORRECTION & UPDATES
If your personally identifiable information changes (such as email, phone number or your billing information), or if you no longer desires our service, you may contact us to correct or update this information.
SPECIAL PROVISIONS FOR USERS COVERED BY THE GDPR
Please note that, as stated above, your data will be stored on our partners’ servers in the USA.
WHICH COUNTRIES ARE COVERED BY THE GDPR
We apply GDPR guidelines for all users in the EU, EEA, the microstates of Andorra, Monaco and San Marino, as well as Switzerland.
YOUR DATA RIGHTS
You have the right to access or rectify the personally identifiable data we hold about you. You also have the right to ask for your data to be deleted. Just keep in mind that we might need it in order to fulfill the rest of your subscription.
If you want to access, rectify or delete your data, please send us an email at support@bang.com
OPTIONAL FEATURES
We ask consent from you to share your data with partners at certain times, as well as to use your email address to send you content updates and special offers from us or our partners. If you do not give us consent to do so we will not share your data and you will not receive these emails. You can change your email marketing setting at any time in your Account Settings.
COMPLAINTS
In the unfortunate case where you are not happy with our privacy notice or processes, and where we can’t resolve the issue together, you have the right to file a complaint with a supervisory authority. This can be the supervisory authority of your country if you’re in the EU/EEA, or otherwise the Maltese Data Protection Authority.
CONTACT
If you have any questions about this Privacy Notice, or if you otherwise need to contact us regarding your personally identifiable information, please contact us by sending an e-mail. Please provide us with your password, user name and account number so we can service you quicker.