BoxHero
Privacy
Policy
Last modified on February 4, 2021
BGPworks,
Inc. (“Company,” “us,” “we,” or “BoxHero”) provides the BoxHero.io website and related web, mobile
and other software programs and applications (collectively, the
“Site”) and takes your privacy and security seriously. This Privacy Policy explains how we collect, use,
share and protect personal data (“Personal Information”) we receive from users.
We collect Personal Information from users when they
view, access, use or register through the Site or use any related services offered
therein (collectively, “Services”). The provision of certain information is
contractually required based on your use of the Services.
This Privacy Policy applies to persons and businesses
anywhere in the world that may access the Site. By using the Site or our Services,
you agree to be bound by this Privacy Policy in full. If you do not wish to
provide Personal Information or be bound by this Privacy Policy, you may not
use the Site or the Services.
The Company reserves the right to modify, change, or
replace this Privacy Policy at any time by updating this document. You agree to
be bound by the most recent version of the Privacy Policy available on the Site.
The date of the last modification will be displayed near the top of the Privacy
Policy.
1. INFORMATION
COLLECTED
(a) Our legal basis for collecting and processing your Personal
Information is (i) your explicit consent when
accessing the Services and (ii) a legitimate interest and need in order to provide
specific Services offered on the Site, as described in our Terms of Service. We
may collect the following Personal Information from users:
i. Information You Provide Voluntarily. We regularly receive and store any information you
enter on the Site or give us in any other way, whether it be through filling
out a form, or through an actual communication. You may elect to not provide
certain information, but such an election may prevent you from taking advantage
of, and accessing many of our features. We use the information that you provide
for purposes such as: responding to your communications and/or requests, customizing
future experiences on the Site for you, improving our stores, and communicating
with you in any other way. The types of personally identifiable information
which may be collected through your use of the Site include, but are not
limited to: your name, physical address, any email address, phone numbers, fax
numbers, billing address, shipping address, product selections or views, order
and/or confirmation numbers, credit card numbers and expiration dates,
referring URLs, IP addresses, passwords, usernames, gender, occupation,
personal interests, your age and information about your hobbies, likes,
interests in and regular use of certain products, programs and other services
you use or may be interested in. You voluntarily provide the above personally
identifiable information to us when you enter such information on the Site,
whether input with the intention of facilitating a purchase, payment,
newsletter subscription, promotion or contest and/or any other special offers
or benefits. You are the source of this
information.
ii. Information Provided Automatically. Upon your use or interaction with the Site, we
automatically receive and store certain types of information. We obtain certain
types of information when the browser you are using accesses the Site or
advertisements therein, and other content served on the Site itself, or on
behalf of the Site through other web sites.
·
Non-Personal Information: We collect non-personally-identifying information of
the sort that web browsers and servers typically make available upon their
interaction with Sites. This information
may include such things as the browser type used during the interaction, the
language preference, the referring website, and the date and time of each
visitor request.
·
Your IP Address: Your Internet Protocol (“IP”) address is a unique
identifying code which is used in connecting your computer to the Internet.
Your IP Address may be used for various purposes, including to: (i) help us identify you, and your purchase orders, and to
gather general and broad demographic information; (ii) help us diagnose or
service technology problems that are associated with the IP addresses
controlled by a specific Web company or ISP; (iii) help us estimate the total
number of Users visiting the Site located in certain geographic locations; and
(iv) help us determine which Users have access privileges or restrictions to
certain content available on the Site.
·
Device Identifier: We may provide services that allow Users to visit,
view, access and customize the Site and other content through the use of their
mobile devices such as: phones, PDAs and
other similar electronic devices. When the Site is accessed through these
devices rather than a computer, different information may be collected. When
you visit or connect with the Site through the use of a mobile device that has
Internet accessibility, in the event that the mobile device service provider
uniquely identifies the device, we will be able to receive this identifying
information. We may use this unique device information to be able to offer
extended services and/or functionality. Certain services, offers you elect to
enroll in, or purchases you wish to make through the Site may require the
collection of the phone number for your device. We may associate and categorize
the phone number collected along with the mobile device information.
·
Your Physical Location: Some mobile phone service providers in the United
States are required to operate using a certain functionality which pinpoints
the physical location of any mobile devices currently using their service.
Depending upon which service provider your device is enrolled with, and if you
are visiting the Site while you are located in the United States, we may
automatically receive this information. We may use and store such information
received in order to assist us in providing opportunities for services based on
your location, as well as to assist with advertising which is targeted based on
location.
·
Web Cookies: For advertising and other purposes as described below,
we use a feature in your Internet Web browser called a “cookie,” which is a
piece of information stored on your hard drive, that identifies your intra- and
inter-requests on the Site. Cookies may be used for various purposes, including
the tracking of your preferences which you indicate while visiting or using the
Site. If you wish to disable the use of cookies, please review the Help section
of your Internet browser, and review the instructions therein on how to turn
off this feature. You can also indicate your choices regarding display
advertising, through the use of specific platforms, which include but may not
be limited to the Digital Advertising Alliance opt-out platform or the Network
Advertising Initiative opt-out platform. To opt-out of these cookies, please
visit the following URLs:
·
http://www.aboutads.info/choices;
·
allaboutcookies.org; or
·
Beacons: Web
pages included on the Site may contain e-images called a “Web beacon,” also
known as a “single-pixel GIF,” which allow a Site to count the number of Users
who have visited that particular page or to access specific cookies and the
information contained therein. We may use such Web beacons for the following
purposes: (a) to count and determine the
number of Users and to recognize such Users through the accessing of Site
cookies, (b) to count, determine, and recognize the number of Users who have
opened or read emails sent to the User by us, and (c) to assist in
personalizing your interaction with the Site to make the experience more
efficient and enjoyable for you.
2.
COLLECTION
THROUGH THIRD-PARTY SERVICES
(a)
We
may use certain third-party services in order to assist in the provision of the
Services to you, and to enhance your experience on the Site. Through your use of this Site, certain
portions of your information may be processed through the following third-party
service providers, and therefore, such processing shall be pursuant to the
terms and privacy policies of such third-party service providers. These third-party service providers may be
subject to change at any time, within the Company’s sole discretion:
i. Email Delivery
·
Mailjet: https://www.mailjet.com/security-privacy/
ii. Tracking
·
Mixpanel: https://mixpanel.com/legal/privacy-policy/
·
App/Web
Metrica: https://metrica.yandex.com/about/info/privacy-policy
·
Google
Analytics:
https://policies.google.com/privacy
iii. Payment Services
·
Stripe: https://stripe.com/privacy
iv. Login Services
·
Facebook: https://www.facebook.com/about/privacy/
·
Google: https://policies.google.com/privacy
·
Kakao Talk: https://www.kakao.com/policy/privacy?type=sp&lang=en
3. SHARING
AND USE OF PERSONAL INFORMATION
(a)
In some instances, we may disclose
certain information about you to third-parties whose practices are not governed
or covered by this Privacy Policy. Due to the current and existing regulations,
we are unable to specifically ensure that any or all of your personal
information and private communications will not ever be disclosed in ways not
covered or defined within the terms herein. One example of such activity may
include the ability of third-parties to unlawfully intercept, access, or
capture certain transmissions of information or private communications. If you
wish for us to not disclose any personal information collected about you in any
of the ways identified and described within this Privacy Policy, you should
refrain from visiting or accessing the Site or any related Services.
i.
News; Offers. In some instances, we may provide certain personal
information which you input while registering or signing up to receive news,
offers, updates, sweepstakes or contests, to trusted, third-party partners who
work directly with us. Such third-parties may use that personal information to
communicate with you about certain updates, offers or surveys from us and/or
such third-parties. If you wish to opt out of receiving such offers and/or
materials, please email your desired request to opt out to: support+boxhero@bgpworks.com.
ii.
Independent Contractors and
Third-Parties. We may have third-party
agents, subsidiaries, affiliates and partners who may perform certain functions
on our behalf, such as marketing, analytics, research, credit card processing,
assisting with customer service, fraud protection, etc. Such third-party
entities have limited access only to the personal information necessary to
perform the roles for which they are associated with us. Such third-parties are
strictly prohibited from using, selling, distributing or altering this data in
any way, or using the information for any activity other than required to
provide the requested services for us and the Site.
iii.
Legal Disclosure. In some instances, we may disclose and release certain
information in response to any legal demand, such as subpoenas, court orders,
or legal process, or to establish or exercise our legal rights or defend
against legal actions or claims brought against us or the Site. We may share
such information in order to investigate, prevent or take action in the event
of any alleged illegal activities, suspected fraud, potential threats to the
physical or financial safety of any person or entity, any violations of our
terms of service, or as otherwise permissible under any applicable law.
iv.
Third-Party Advertisers. In some instances, we may collect certain personal
information about you and share it with other third-parties, to the extent that
you grant permissible upon collection of such information. We may show certain
targeted advertisements on the Site during your use, based on personal information
you provided to us upon registering your account. Advertisers (including ad
serving companies) may assume that certain people who interact with, view or
click on targeted ads, meet the targeting criteria (for example, women ages
18-24 from a particular geographic area). By clicking on or viewing a
particular ad, you are thereby consenting to the possibility that the
advertiser will make the assumption that you meet the targeting criteria used
to determine whether to show you such an ad. We may gather certain personal
information about you on behalf of a sponsor or advertiser who is facilitating
a particular promotion. In such an instance, we will provide you with notice of
such, at the time of the collection on the sponsor or advertiser’s behalf. Upon doing so, we may link you to the sponsor
or advertiser’s privacy policy.
v.
Sharing Within Organization. In some instances, we may share your personal
information with any of our subsidiaries, joint ventures, or other companies or
entities which fall under common control. In the event that we transition
through merger, acquisition by another company, or sale of all or a portion of
our assets, your personal information may be included and among the assets to
be transferred in such a transition. You hereby acknowledge and agree that such
transfers may occur, and that such transfers are permitted under the terms of
this Privacy Policy.
vi.
Some
various ways in which we may use your Personal Information are as follows:
·
To
provide content, inventory access/features, and other various forms of information
as it pertains to the Services.
·
To
verify your account and user identity and to comply with laws to which we are
subject.
·
To
contact you about the Services or the Company.
·
To
provide customer or technical support.
·
To
analyze and improve the features and performance of the Services and to analyze
usage patterns.
·
To
inform Users about offers from the Company.
(b) We care about your
privacy. We will not sell or share your Personal Information with third parties
other than as expressly provided for in this Privacy Policy.
4. THIRD PARTY LINKS
(a) You may encounter links to third party websites, videos,
pictures, and applications (“Third-Party Links”) when using the Services. We
cannot control the content on these Third-Party Links and we can make no
guarantees as to the protection and privacy of any information which you submit
to these Third-Party Links. Please exercise caution when accessing Third Party
Links.
5. CHILDREN
(a)
We do not
knowingly collect Personal Information from any child under the age of 13.
Further, you may not use the Site unless you are at least 18 years of age. Please note that the Service is not for use by
individuals under 18 years of age. You acknowledge and consent to taking such
steps as are necessary in order to verify your identity and your age for the
purposes of complying with applicable law, in order to use the Site. If you believe we
have collected Personal Information from a child under the age of 13, please
contact us immediately.
6. SECURITY
(a)
We use commercially reasonable
methods of protecting your Personal Information. Nevertheless, we cannot guarantee
the safety or security of any Personal Information. Further, transmission of
Personal Information cannot be made completely secure. For that reason, you
agree to transmit Personal Information to the Company solely at your own risk.
7. DO NOT TRACK POLICY AND PROCEDURES
(a) We do not currently respond to “do not track” browser
headers or specific “do not track” requests. You do have the ability to
limit tracking through these third-party programs and by taking the actions
listed below. The use of online tracking mechanisms by third-parties is
governed by those third-parties’ own privacy policies, and not the terms
included hereunder. If you prefer to prevent third-parties from setting and
accessing cookies on your computer, you may adjust the settings of your own web
browser to block the placement of cookies. You may remove yourself from the
targeted advertising of companies by contacting the Network Advertising
Initiative, or of companies participating in the Digital Advertising Alliance
program by contacting them directly.
8. YOUR CALIFORNIA PRIVACY RIGHTS
(a)
Supplemental
Privacy Notice to California Residents:
i. If you are a resident of
California, California Civil Code Section 1798.83 permits you to request
information regarding the disclosure of your personal information by Wild Tree Holdings, LLC or its subsidiaries to a third-party for the third-party’s direct
marketing purposes. This right is
granted to California residents and applies only to their activities within the
State of California. To make such a
request, please send an email to: support+boxhero@bgpworks.com or write us at:
· BGPworks, Inc.
BoxHero.io
ATTN: CA Privacy Rights
216, 6, Wangsimni-ro 10-gil, Seongdong-gu,
Seoul, Republic of Korea
ii. In your request, please specify
the BGPworks company or subsidiary to which your request pertains. If no company is specified, we will treat
your request as pertaining to BGPworks, Inc.
9. SHIELD ACT COMPLIANCE
(a) The safety and security of your private
information is extremely important to us.
As such, we have adopted and implemented reasonable safeguards to
protect the security, confidentiality, and integrity of your private information.
These safeguards are documented in our data security program which contains
specific measures which we have undertaken to ensure the protection of your
information. You may view a copy of our
data security program here: https://www.heroku.com/policy/security,
https://aws.amazon.com/security/. In the
event of a suspected breach, to the extent we determine is required by
applicable law in our sole discretion, we will provide notice of such a breach
to you through any of the legally permissible methods of communication
available to us. In the event of a
determination being made that notification of a breach is not necessary, such
determination will be documented and stored for the duration of the legally
required time. For any further questions
regarding our compliance with the Shield Act and your rights thereunder, please
contact us at: support+boxhero@bgpworks.com.
10. INTERNATIONAL PRIVACY PRACTICES
(a)
The Company is primarily operated
and managed on servers located and operated within the United States. In order
to provide our Services to you, we may send and store your Personal Information
outside of the country where you reside or are located, including to the United
States. Accordingly, if you reside or are located outside of the United States,
your Personal Information may be transferred outside of the country where you
reside or are located, including countries that may not or do not provide the
same level of protection for your Personal Information. We are committed to
protecting the privacy and confidentiality of Personal Information when it is
transferred. If you reside or are located within the European Economic Area and
such transfers occur, we take appropriate steps to provide the same level of
protection for the processing carried out in any such countries as you would
have within the European Economic Area to the extent feasible under applicable
law. By using and accessing our Services, Users who reside or are located in
countries outside of the United States agree and consent to the transfer to and
processing of Personal Information on servers located outside of the country
where they reside, and that the protection of such information may be different
than required under the laws of their residence or location.
11. RETENTION, CORRECTION, AND DELETION
OF PERSONAL INFORMATION
(a) Personal Information
that we process shall not be kept for longer than is necessary for the relevant
purpose. We will retain your Personal Information as follows:
i. Personal Information will be retained for as long as you
have a User Account (as described in our Terms and Conditions of Use) or as
required by law or our own backup and security policies.
ii. We will comply with any user’s
requests regarding access, correction, and/or deletion of the Personal
Information we store in accordance with applicable law, including the EU
General Data Protection Regulation (GDPR). To request that we correct, delete,
or export any Personal Information, please contact us via email at support+boxhero@bgpworks.com.
iii. To delete your account, please
proceed with the followings:
From BoxHero mobile app: Sign in and go to the
Settings → Support → Delete Data → Delete Account
From BoxHero web: Sign in and go to the Payment &
Settings → General → User Info → Delete Account
Even after the account deletion, however, we may still retain your data for
dealing with us in the event of complaints, disputes, challenges, and/or
litigations regarding your data as well as to follow legal obligations
including our Terms of Service, tax, and/or accounting requirements.
iv. To further request that we
correct, delete, or export any Personal Information, please contact us via
email at support+boxhero@bgpworks.com.
12. PERSONAL INFORMATION WILL BE SENT TO
THE UNITED STATES
(a) The Company is based in
the United States and your Personal Information will be processed in the United
States. The hosting facilities for your Personal Information are in the United
States. United States laws may be less strict than those of your own country.
13. YOUR
RIGHTS UNDER THE EU GENERAL DATA PROTECTION REGULATION (GDPR)
(a) Your principal rights
under the EU General Data Protection Regulation (GDPR) are as follows:
i. Right of Access: you have the right to be informed of, and request
access to, the Personal Information we process about you.
ii. Right to Rectification: you have the right to request that we amend or
update your personal data where it is inaccurate or incomplete.
iii. Right to Erasure: you have the right to have the Company delete your
Personal Information.
iv. Right to Restrict: you have the right to request that we temporarily
or permanently stop processing your Personal Information.
v. Right to Object: you have the right to object to us processing your Personal
Information on grounds relating to your particular situation or for direct
marketing purposes.
vi. Right to Data Portability: you have the right to request a copy of
your Personal Information in electronic format and the right to transmit that
personal data for use in another party’s service.
vii. Right not to be Subject to Automated Decision Making: you have the
right to not be subject to a decision based solely on automated decision
making, including profiling, where the decision would have a legal effect on
you or produce a similarly significant effect.
14. DATA CONTROLLER AND HOW TO CONTACT
US
(a) The Personal Information we collect and process is
controlled by BGPworks, Inc., a Delaware corporation located in the United
States. You may contact us at 216, 6, Wangsimni-ro
10-gil, Seongdong-gu, Seoul, Republic of Korea, or by
email at: support+boxhero@bgpworks.com.