OUR APPROACH TO PRIVACY
1.1 Besta SASU and Affiliates ("Besta", “Miracamp”, "we", " our", or "us") are committed to protecting and respecting your privacy. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (" personal information") and information regarding our use of cookies and similar technologies. 1.1 Besta operates a training platform, that allows users to centralize & run all their training initiatives ("Besta Service"). 1.2 This privacy policy applies to the Besta Service. Before accessing or using the Besta Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this privacy policy. 1.3 We are the data controller of the personal information we hold about you. This means we determine and are responsible for how your personal information is used.
PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
2.1 We collect personal information that you voluntarily submit directly to us when you use the Besta Service. This can include information you provide to us when you register for an account, fill in a form on the Besta Service, create or edit your user profile on the Besta Service, correspond with us by phone, e-mail or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to a survey, post comments in discussion groups, enter a promotion, or use some other feature of the Besta Service. 2.2 We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Besta Service. If you choose not to provide such personal information, we may not be able to provide those parts of the Besta Service to you or respond to your other requests. 2.3 Annex 1 sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information. 2.4 We also automatically collect personal information indirectly about how you access and use the Besta Service and information about the device you use to access the Besta Service. 2.5 Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information. 2.6 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us. 2.7 We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Besta Service and developing new products and features. We may also share such anonymised information with others. 2.8 We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2, and in any event for no longer than 13 months after collection, in accordance with our legal obligations and legitimate business interests.
RECIPIENTS OF PERSONAL INFORMATION
3.1 In addition to the recipients listed in Annex 1 and Annex 2, we may also share your personal information with the following (as required in accordance with the uses set out in Annexes 1 and 2): (a) Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, email or chat services, fraud prevention, web hosting, or providing analytic services. (b) Third parties through technology integrated with the Besta Service : We may collect certain personal information through software provided by our partners, such as Google Analytics which we integrate into the Besta Service. These partners may have access to the personal information collected in this way in order to maintain this software and provide us with services, such as calculating usage analytics in relation to the Besta Service. (c) Affiliates. Other companies owned by or under common ownership as Besta, including our subsidiaries (i.e., any organisation we own or control) and our ultimate holding company (i.e., any organisation that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy. (d) Purchasers and third parties in connection with a business transaction : your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business. (e) Law enforcement, regulators and other parties for legal reasons : we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Use; and/or (iii) exercise or protect the rights, property, or personal safety of Besta, its users or others.
MARKETING AND ADVERTISING
4.1 From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services. 4.2 Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you. 4.3 We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by updating your preferences through the Besta Service.
STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
5.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers. 5.2 International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Union ("EU"), your personal information may be processed outside of the EU including in the United States. 5.3 In the instance of such a transfer, we ensure that, either: (a) the personal information is transferred to countries recognised as offering an equivalent level of protection; (b) the personal information is transferred to certified entities under the EU-U.S. Privacy Shield; (c) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this privacy policy.
YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
6.1 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold: (a) Right of access. You have the right to obtain: (i) confirmation of whether, and where, we are processing your personal information; (ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods; (iii) information about the categories of recipients with whom we may share your personal information; and (iv) a copy of the personal information we hold about you. (b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person. (c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay. (d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified. (e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you. (f) Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason. 6.2 If you are resident in France, you also have the right to set guidelines for the retention and communication of your personal information after your death. 6.3 If you wish to exercise one of these rights, please contact us at support@bestapeople.io. 6.4 You may also review and edit some of the personal information you have submitted to us by logging into your account on the Besta Service. 6.5 Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document. 6.6 We will seek to respond to any request relating to your rights within one month of receipt of such request. 6.7 Where, given the complexity of the claim or the number of requests received, the above deadline cannot be met, we will inform you of the exTended deadline in which we will respond to your request. Such extension may not be more than two months from the date on which we notify you that an exTension is required. 6.8 We are entitled to object to requests which are clearly abusive in their number or in their repetition. 6.9 Where we do not follow up on your request, we will inform you within the one month deadline of the grounds on which we have based our decision and of you right to refer a complaint to your national data protection authority.
LINKS TO THIRD PARTY SITES
7.1 Our Besta Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
OUR POLICY TOWARDS CHILDREN
8.1 Our Besta Service is not directed at persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
CHANGES TO THIS POLICY
9.1 We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
NOTICE TO YOU
10.1 If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Besta Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.
CONTACTING US
11.1 Please contact support@bestapeople.io if you have any questions, comments and requests regarding this Privacy Policy. 11.2 If we are unable to deal with any issues you raise with us, you also have the right to lodge a complaint with your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. 11.3 This privacy policy was last modified on April 2019.
ANNEX 1 – PERSONAL INFORMATION WE COLLECT
Phone number - We may use this information to operate, maintain and provide to you the features and functionality of the Besta Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
Profile information - We may use this information to identify users. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
Chat, comments and opinions - We may use this information to:
Operate, maintain and provide to you the features and functionality of the Besta Service. The processing is necessary for our legitimate interests, namely developing and improving the Besta Service or certain features of the Besta Service
Address your questions, issues and concerns, develop new products and features available through the Besta Service or otherwise improve the Besta Service. The processing is necessary for our legitimate interests, namely developing and improving the Besta Service or certain features of the Besta Service
Recommend content and other features available through the Besta Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
Information about your use of our Service - We may use this information to :
Operate, maintain and provide to you the features and functionality of the Besta Service. The processing is necessary for our legitimate interests, namely developing and improving the Besta Service or certain features of the Besta Service
Address your questions, issues and concerns, develop new products and features available through the Besta Service or otherwise improve the Besta Service. The processing is necessary for our legitimate interests, namely developing and improving the Besta Service or certain features of the Besta Service
Recommend content and other features available through the Besta Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
All personal information set out above - We may use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Besta Service, to communicate with you, to monitor and improve the Besta Service and business, and to help us develop new products and services. The processing is necessary for our legitimate interests, namely to administer and improve the Besta Service.
ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY
All the personal information listed below will be shared with the following:
Google Analytics to track events on our platform;
Google Suite, Microsoft, Slack, SSO providers to enable authentication process
List of personal information collected automatically:
Approximate location information. Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may however help us determine an approximate location. We may use information you provide to us about your location to inform and plan our marketing strategy. The processing is necessary for our legitimate interest, namely informing our direct marketing strategy.
Information about how you access and use the Service. For example, how frequently you access the Besta Service, the time you access the Besta Service and how long you use it for, the approximate location that you access the Besta Service from, whether you access the Besta Service from multiple devices, and other actions you take on the Besta Service. We may use this information to:
Present the Besta Service to you on your device. The processing is necessary for our legitimate interests, namely to tailor the Besta Service to the user
Determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing
Monitor and improve the Besta Service and business, resolve issues and to inform the development of new products and services. The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Besta Service and to improve the Besta Service generally.
Log files and information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to the Besta Service. This information can include details about the type of device, unique device identifying numbers (such as your Google Advertising ID or Unique ID for Advertisers), operating systems, browsers and applications connected to the Besta Service through the device, your mobile network). We may use this information to:
Present the Besta Service to you on your device. The processing is necessary for our legitimate interests, namely to tailor the Besta Service to the user
Determine products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing
Monitor and improve the Besta Service and business, resolve issues and to inform the development of new products and services. The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Besta Service and to improve the Besta Service generally.