Privacy Policy – App

BAITCAMP

Effective Date: September 15, 2020

In the event of a conflict, the English language version shall govern.

Introduction

W we are committed to protecting the privacy of your data. This Privacy Policy explains more specifically what information PHH Digital and its Group Companies (together, “BAITCAMP,” “we” or “us”) collect, use, and disclose about you when you access or use our websites and applications, which we refer to collectively as “the Service,” contact our customer service team, engage with us on social media, or otherwise interact with us. The Service includes the BAITCAMP Software.

Although significant changes are rare, this policy may be amended as new features, technology, or legal requirements arise, so please check back from time to time. We’ll notify you if we make a significant change and, where required, seek your consent.

What information does BAITCAMP collect?

We built BAITCAMP to help you organize your trips, diary, and photos. That means you can input, upload, or store in BAITCAMP any text, images, and other data that you choose—we refer to that information as “Content”. We also collect and receive the following types of information:

• Basic subscriber information. To open your account, we collect and receive identifiers like your email address and full name.
• Usage data. We collect and log Internet or other electronic network information on how you and others access and use BAITCAMP, for example, the act of creating a diary or sharing a diary. .
• Location information. We collect t— if you choose to share it — your location information from a mobile device.
• Device information. We collect information about the number and type of devices you use to connect to the Service, as well as information about the operating systems on those devices (e.g., iOS, Android)..

We also may link your subscriber information with data we receive from our partners and other third parties to help understand your needs and provide you with a better experience.

We’ve listed the types of information we collect and receive more specifically in the chart below. Generally, we collect this information to support your account and to help us understand how you use the Service so we can make it better. We have noted which types of information are not collected unless you choose to provide it.

If you register for or maintain an BAITCAMP service account:

How does BAITCAMP use my information?

We have specific rules for how and when we use the information we collect and receive. We describe these below.

What does BAITCAMP do with my information?

We are committed to protecting the privacy of your information. Below, we describe the ways in which we use the information we collect and receive to provide, maintain, and improve the Service; to provide troubleshooting and customer support; to protect the Service for all our users; to contact you.

• Performing our Services. We use a number of technologies to help you get the most out of the Service. Our systems automatically analyze your data to power BAITCAMP features and to continually improve the Service for you in a way that does not require anyone to look at your Content. This may include, for example:
  • Making sure you find what you’re looking for when you search your account.
  • Showing you information most relevant to how you are or could be using the Service at a specific time or location.
  • Suggesting actions for you to take based on information you’ve stored.
  • Suggesting BAITCAMP service features or products to you that we think will help you get the most out of our Service.

• Maintaining our Services. To provide troubleshooting and customer support, our Customer Support team may need to access your information, such as your account email address and information about the BAITCAMP application you are using, subject to the protections described below.
• Communicating with you. In accordance with your communication preferences, we’ll occasionally contact you to announce new products and features we build for you, share tips for using BAITCAMP to get more done, make special offers, and provide information about how BAITCAMP works with products and services from our business partners.

You can change your in-app notification preferences through your device settings. You will continue to receive essential Service-related and account-related information (such as notification that your paid subscription is about to expire), even if you unsubscribe from promotional emails or turn off in-app notifications.

Similarly, if we learn of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address, phone number or other contact information that you have provided to us or by posting a notice on our web site and/or via other communication platforms. Depending on where you live, you may have a legal right to receive such notices in writing.

• Complying with Law. BAITCAMP also uses information to satisfy applicable laws or regulations, and discloses information in response to legal process or enforceable government requests, including to law enforcement. For more information, please visit the section “How does BAITCAMP respond to legal requests for my information? ” of this Privacy Policy.

Would someone at BAITCAMP ever view my Content?

You have control over who sees your Content. We limit the use of your Content to make sure that no one at BAITCAMP can view it unless you expressly give us permission or it’s necessary to comply with our legal obligations. Specifically:

• To help refine or improve the technology, we may ask you for permission to review portions of your Content. For example, if a new feature suggests related notes that are relevant to your Content, we may give you an opportunity to provide us feedback on how well the feature is performing along with a sample of the Content in question, so we can make sure this feature provides appropriately tailored suggestions. Such access to your Content is done only with your express permission and is subject to strict confidentiality rules and data access controls. Choosing to give us such permission is completely voluntary.
• If you contact our Customer Support team for help with specific pieces of Content in your account (for example, if you can’t find a note you believe should be in your account), we may ask for your temporary permission to look at your Content. This permission terminates when the issue is resolved.

If you send BAITCAMP an error report and choose to attach application activity logs, please note that such logs may contain Content (for example, the title of a diary entry). You may edit Content out of your activity logs before you send them to us.

To test and improve our product offerings for our users, we use aggregated data that does not contain any personal information, does not identify any person, and cannot be connected to any specific user. This policy is not intended to apply to such anonymized/de-identified data.

How does BAITCAMP share or disclose my information?

BAITCAMP is not in the business of selling or renting your information. Here are instances when we may disclose your information — and then only the minimum information necessary:

• We share your information with service providers who process data on our behalf, such as credit card processors and customer management systems. For example, these service providers help us:
  • Operate, develop, and improve the features and functionality of the Service
  • Complete your payment transactions
  • Fulfill your sales and support requests
  • Communicate with you as described elsewhere in this Privacy Policy

We require these providers to agree to strict data protection requirements in keeping with our privacy policy standards and our obligations under data protection laws.

We do not share your information with any third parties for their own advertising purposes.

Examples of our service providers include PayPal and Stripe for processing payments from our paid users, MailerLite for helping us with our email communications and BAITCAMP outreach, and analytics providers like Google Analytics. Other service providers include resellers that we work with to help distribute BAITCAMP.

• Your Content is private unless you decide you want to share it. You may choose to share using public links or through any of the Service’s features that allow you to share or collaborate on Content (“Collaboration Features”). If you choose to share, we may need to take steps to facilitate your collaboration.

There are features in BAITCAMP that allow you to publish and share some of your diary entries and photo publicly, but these are optional. Any information that you post in these locations, or in our user forum, can be read, collected, and used by anyone and could enable others to send you unsolicited messages. BAITCAMP enables you to determine whether to post personal or otherwise sensitive information to publicly accessible areas of our site, so you should carefully consider how you use the Service. BAITCAMP is not responsible for any publication or use of any information you choose to post in these locations.

When you use Collaboration Features, people you share with may see your user profile.

• If you have not added any profile information, then you will be identified by the email address associated with your BAITCAMP service account.

In addition, when you use Collaboration Features, the information you share is no longer private to you. For example, by publishing or sharing any portion of your Content, you may be enabling each recipient of the shared material to access, use, display, perform, distribute, and modify that material. In addition, BAITCAMP enables you to use a variety of third-party services and applications that interact with the Service, and you should review the access rights you provide to those services or applications, as you may enable them to access or extract your Content through your agreements with those parties. .

Depending on the permission levels you set when sharing Content, anyone who has access to the shared material may be able to see the Content, information about where and when the Content was created, as well as the note history, tags, and reminders associated with a particular note.

• In the event of a merger, sale, or reorganization of all or part of our business, information covered by this policy may be transferred in connection with that deal.
• Wwe contract with third-party advertising networks in order to deliver relevant BAITCAMP advertisements to you across the Internet and to manage our communications with you. We do not use your Content for these purposes. In addition, we may share with partners or service providers a hashed identifier to serve you relevant BAITCAMP ads when you visit partners’ and providers’ websites, applications or platforms. We may, for instance, participate in the Google Adwords Remarketing, Twitter Tailored Audience and Facebook Custom Audience services. To learn more about the privacy controls that Google, Twitter and Facebook offer and honor for those respective services, please visit here for Google, here for Twitter, and here for Facebook. You may opt out of certain ad targeting and retargeting services by visiting the Digital Advertising Alliance’s opt-out page, or the Network Advertising Initiative’s opt-out page.
• We also may share information about you with third parties whenever you consent to or direct such sharing..

How does BAITCAMP respond to legal requests for my information?

We vigilantly protect the privacy of your account. We will not disclose your information to law enforcement or other governmental authorities unless we believe it is required to comply with warrants, court orders, subpoenas, or other lawful government requests. This may include responding to legal requests from jurisdictions outside of the United Kingdom where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards of due process.

We narrowly interpret all information requests, and we only disclose Content in your account that is specifically responsive to a government warrant or where you have provided your explicit consent. We will notify you if we believe we are compelled to comply with a third party’s legal demand for your information, and we routinely push back on government orders to delay user notice that we view as overly broad..

In addition, in rare cases, we may share your information as necessary to investigate or take action regarding illegal activities, suspected fraud, or potential threats against persons, property or the systems on which we operate the Service, or as otherwise necessary to comply with our legal obligations.

How can I manage my information stored in BAITCAMP?

Consistent with our first law of data protection—your data is yours—in most cases, you can manage your information simply by logging into your account and editing your information directly within the BAITCAMP Service.

However, if you prefer, you can contact us at [email protected] to ask us to provide access to, correct, update, or delete your personal information. California residents should visit the section “Your California Privacy Rights” of this Privacy Policy for more information about specific rights and how to exercise those rights. Please note that we may ask you for proof of account ownership and/or identity before fulfilling your request. We will comply with such requests to the extent required by applicable law or the US-Swiss Privacy Shield and US-EU Privacy Shield Frameworks.

A Note for our European End Users about our Data Processing Grounds and your Data Access Rights

We process personal data originating from the European Economic Area (“EEA”), the United Kingdom, and Switzerland on one of three grounds, depending on the circumstances: (i) your affirmative consent, in which case you will have the right to withdraw consent at any time; (ii) contractual necessity; or (iii) our legitimate interest in providing the Service.

Below is an explanation of the the data access rights BAITCAMP makes available to EEA, UK and Swiss individuals.

How long does BAITCAMP store my information?

If you delete your Content and then sync, it will no longer be accessible to you or others who may access the Service. The BAITCAMP service’s back-up systems may retain residual copies of your deleted Content for up to one year due to the nature of those systems’ operations.

For users who are inactive for extended periods of time, we may close your account to satisfy our obligations under applicable law, and in accordance with our data retention policy. If that happens, we will try to notify you before taking any action.

What happens if I want to stop using BAITCAMP?

As described above, you can delete your Content at any time, and you can stop using the BAITCAMP service at any time. And as we promise in our third law of data protection, your data is portable.

What happens if BAITCAMP closes my account?

If BAITCAMP deactivates your account due to a TOS violation, then you may contact us to request deletion of your Content, and we will evaluate such requests on a case by case basis, pursuant to our legal obligations.

Where does BAITCAMP store my information?

When you use BAITCAMP Software on your computing device, such as by using one of our downloadable applications, some of your data will be stored locally on that device.

When you sync your computing device with the Service, that data will be replicated on servers maintained in the United States. This means that if you store information in or submit data to the BAITCAMP website or BAITCAMP Software and sync such BAITCAMP Software with the BAITCAMP service, you acknowledge your personal information will be transmitted to, hosted, and accessed in the United States.

Data privacy laws or regulations in your home country may differ from, or be more protective than, those in the United States. We will collect, store, and use your personal information in accordance with this Privacy Policy and applicable laws, wherever it is processed.

Which BAITCAMP company is my data controller?

Your data controller is PHH Digital (UK).

Your California Privacy Rights

Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”) (California Civil Code Section 1798.100 et seq.). If you are a California resident, these terms and conditions apply to you.

We do not and will not sell your personal information. BAITCAMP uses and collects your information for the purposes described in this Privacy Policy, which include “business purposes” under the CCPA.

California Consumer Privacy Act

We provide the following additional disclosures related to the collection, use, and disclosure of personal information under the CCPA:

• Categories of Personal Information Collected. In the preceding 12 months, we have collected the categories of personal information listed below.
  • Identifiers such as your first name, last name, email address, IP address, unique device identifiers or other online identifier;
  • Commercial information such as your payment method and related information if you purchase a subscription;
  • Internet or other electronic network activity information, including connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address;
  • Interaction with our software or apps such as usage data, type and version of operating system, hardware version, device settings, software types, battery and signal strength, screen resolution, device manufacturer and model, language, and Internet browser type and version;
  • Audio, electronic, visual, or similar information, such as photos that you upload to your account or otherwise provide to us;
  • Other information that relates to or is capable of being associated with you, including categories we may associate with you, based on the information we or our partners collect, so that we may contact you with messaging that we think will interest you.

For additional examples of the types of data we may collect, see the section “What information does BAITCAMP collect?” of this Privacy Policy.

• Business or Commercial Purpose for Collecting Information. We collect personal information for the business and commercial purposes described in the section “How does BAITCAMP use my information?” of this Privacy Policy.
• Categories of Sources of Personal Information. We collect personal information directly from you when you interact with our Services, automatically when you access or use our Services or transact business with us, and from third-party sources as described in the section “What information does BAITCAMP collect?” of this Privacy Policy.
• Categories of Third Parties with Whom We Share Information. We may share your personal information with third parties as described in the section “How does BAITCAMP share or disclose my information?” of this Privacy Policy.
• Categories of Personal Information Disclosed. In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes: identifiers, commercial information, biometric information, Internet or other electronic network information, and geolocation data.
• Sale of Personal Information. BAITCAMP does not, and will not, sell the personal information of our users. BAITCAMP has not sold the personal information of our users for a business or commercial purposes in the preceding 12 months.

Your Consumer Rights

California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting personal information, the categories of third parties with whom we share your personal information, and the categories of personal information we have disclosed about you in the preceding 12 months. If you are a California consumer, you also have the right to (i) request deletion of your personal information (subject to certain exceptions), (ii) opt out of sales of personal information, and (iii) receive equal service and price and not be discriminated against even if you exercise any of your other CCPA rights.

California consumers may make requests by following these instructions:

• You may email your request to [email protected]. In the subject line of your email, please write “CCPA Rights Request.”

Note that in order to fulfill your request, we may need you to provide certain information to verify your identity. You can also designate an authorized agent to exercise these rights on your behalf. We will not discriminate against you if you choose to exercise your rights under the CCPA.

The BAITCAMP Service is accessible to consumers with disabilities. Consumers with disabilities may also contact us by emailing [email protected] to request an alternative format of this Privacy Policy.

Does BAITCAMP allow children to use its Services?

Our Services are designed for adults, not children under the age of 16. As such, we do not intend to collect personal information from children under the age of 16, and our Services are not designed to manage such information. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].

How does BAITCAMP respond to Do Not Track signals?

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, BAITCAMP does not currently respond to or otherwise take action in response to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an individual consumer’s online activities over time and across third party websites or online services. For information about Do Not Track, visit www.allaboutdnt.org.

How can I contact BAITCAMP?

BAITCAMP welcomes your feedback regarding this Privacy Policy. If you have questions, comments or concerns about this Policy, please contact us by email at [email protected]