Last updated September 18, 2018
Bolster LLC (Bolster) takes the protection of your data seriously. We believe it is critical for you to have meaningful control over your data. With that in mind, we want to be transparent about the personal information we collect about you, how we use it and with whom we share it.
- When you visit our websites, even if you are just reading them, we receive some personal information from you like your IP address, geographic location, and data about how you are using the websites.
- When you interact with us, such as expressing interest in becoming a customer, downloading materials from or viewing demos through the websites, or registering for or attending one of our events, you may share additional information with us like your name, email address, phone number, and information about your educational institution or nonprofit. We use this information to contact you regarding your interest, better understand you and the markets we serve, and improve and tailor the content and services we offer to you.
- Throughout this Policy we’ll refer to ourselves as “we,” “us,” and “our.” Depending on how you are using our websites, we may refer to you as a user, visitor, customer or an attendee depending on what applies.
TABLE OF CONTENTS
- Personal Information We Collect
- How We Use Your Personal Information
- How We Share Your Personal Information
- European Users
- Additional Information
This Policy applies to a variety of Bolster users who visit our websites, including those who download or view website materials (“visitors”), register to use the Services as defined below (“customers”), and register for or attend our online webinars or in-person events (“attendees”).
OTHER APPLICABLE POLICIES
CHANGES TO THE POLICY
PERSONAL INFORMATION WE COLLECT
PERSONAL INFORMATION YOU SHARE WITH US
We collect personal information directly from you including when you request information or Services, become a customer, or fill out a registration or contact form.
When you inquire about becoming a customer, we need you to provide us with your name and email address so that we can determine availability of and the best Services for you.
REGISTRATION OR CONTACT FORMS
To access or take advantage of certain Services, we will require or request that you fill out a registration or contact form through the Sites, including to attend in-person events or educational webinars, view or download materials (e.g. white papers, e-books or demos), join our mailing list, participate in surveys and contact us with your interest. We use the forms you fill out and the information you provide to contact you, enable access to the requested Services, understand our users, obtain feedback and improve our Services. Please note that these forms may include additional policy disclosures.
ADDITIONAL PERSONAL INFORMATION WE RECEIVE ABOUT YOU
We collect personal information about you from Bolster and other third parties. We also receive information about you through additional means.
We work with third-party service providers to assist us in operating the Services, and they send us personal information about you through the course of this relationship. These third parties help us evaluate the security of our Services, detect and prevent fraud, process secure payments, verify our customers, analyze content on our Sites, perform maintenance or auditing functions, and provide marketing and development services. They also receive your personal information to ensure the usefulness, applicability and reliability of our Services and send it to us.
When we work specifically in conjunction with our third-party advertising service providers, we also receive additional personal information about you, such as your language and advertising preferences, transaction or download details, and the website or app advertising or content that lead you to our Services, as further explained in an earlier section and another earlier section.
Bolster may a number of different types of partners, including consulting partners, independent software vendors (“ISVs”), and sponsors, who also serve the nonprofit and education communities (collectively, our “partners”). These partners can assist you in your implementation of your Services or provide you with additional applicable services and resources. When you utilize the services of these partners, we obtain (or share) personal information about you from and/or with Bolster or the partners. This personal information includes your name, business contact details, and organization details and will be used for authentication, access, assisting you in setting up and/or personalizing your use of the Services, and overcoming technical issues.
PUBLICLY AVAILABLE INFORMATION AND SOURCES
When you express interest in becoming a customer, attend our events or webinars, or participate in any programs we may run, we receive and use personal information about you from publicly available sources and other resources. This personal information includes your name, job title, email address, phone number, as well as the name of the Chief Executive Officer of your organization, to determine your eligibility, validate accurate contact information, and for marketing purposes.
We receive and log information about your usage of our Services even if you are just visiting. We refer to this information as “usage data.” For example, when you view pages on our Sites, click on links, download information, sign into your Bolster Account, click on a link through an email we send you, share content on social media, or visit a third-party website that includes our content, cookies (or similar technologies) or ads, we receive information about you.
This usage data includes your Internet Protocol (“IP”) address, browser information, operating system, proxy server, plug-ins, integrations, geographic location, internet service provider, mobile carrier, device information and features, search terms, the referring website, app or ad, pages visited, advertising and language preferences, and cookie information. We also receive usage data concerning the time and frequency of your use of the Sites and when you view or interact with content (e.g. different pages or links of the Sites or a blog) or advertisements (on or off our Sites, including advertisements placed by third parties on our behalf). We use usage data to operate our Services, ensure the secure and reliable performance of our Services, and provide a tailored experience, including ads.
We keep track of how you interact with links across our Services, including links in emails we send you and links that appear on third-party websites or apps.
If you click on an external link from our Services, that advertiser, website operator or organization will be able to figure out that you came to them from us, along with other information associated with the ad you clicked on, such as the audience it was designed to reach. They may collect other personal information from you, such as your IP address, and send it back to us.
COOKIES AND SIMILAR TRACKING TECHNOLOGIES
Bolster collects information on you as you navigate our Sites, or use information based on your navigation of our Sites (“Web Site Navigational Information”). The information is collected through the use of commonly-used information-gathering tools, such as cookies, pixels, tags, and web beacons. Information stored in cookies or similar technologies (collectively, “Identifiers”) generally includes standard information from your web browser (such as browser type and browser language), your IP address, and actions you take on the Sites (such as the web pages viewed and links clicked).
HTML5 WEB STORAGE
Bolster and third parties also utilize HTML5 local or session storage for functional and performance purposes. HTML local or session storage are different from browser cookies in terms of how data is stored, and the amount and type of data that is stored.
HTML5 web storage has a similar breakdown of persistent versus session-based storage. Local storage is persistent-based and session storage is session-based. You can control the use of HTML5 web storage at the individual browser level, but if you choose to disable HTML5 web storage, it will limit your use of certain features or functions of our Sites or Services.
WEB BEACONS, PIXELS, AND OTHER TRACKING TECHNOLOGIES
Bolster may use other technologies, including web beacons, tags and pixels, alone or in conjunction with cookies, to compile information about visitors’ usage of our Sites, applications and email interactions with Bolster. Web beacons are small, clear electronic images that help deliver cookies, collect information about your use of our Sites and Services and are used by Bolster to operate and improve our Sites, Services and email communications.
LOG FILES, IP ADDRESSES, URLS AND OTHER DATA
As is true of most websites, we gather certain information automatically to analyze trends in the aggregate and administer our Sites. This information includes your IP address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information and date/time stamps associated with your usage.
Due to Internet communications standards, when you visit or use our Sites, we automatically receive the URL of the website from which you came and the website to which you go when you leave our Sites. This information is used to analyze overall trends; to help us improve our Sites, services, and applications; and to provide our Services. For example, Bolster uses IP addresses to monitor the regions from which customers and visitors navigate our Sites.
SOCIAL MEDIA FEATURES AND SINGLE SIGN-ON
Our Sites may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect your IP address and which page you are visiting on the Sites, and set a cookie to enable the feature to function properly. You may be given the option by the Social Media Features to post information about your activities on the Sites to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social Media Features are either hosted by a third party or hosted directly on our Sites.
Your interactions with these features are governed by the privacy or cookie policies of the company providing the relevant Social Media Features.
DO NOT TRACK
Currently, various browsers — including Internet Explorer, Firefox, Chrome and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Sites visited by the user about the user’s browser DNT preference setting. We do not currently respond to browsers’ DNT signals with respect to the Sites. Bolster takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
TYPES OF IDENTIFIERS
Bolster uses the following different types of Identifiers.
Required identifiers enable you, and are essential, to access and navigate the Sites and related features and content. These identifiers are set in response to actions by you, like a request for services, i.e., they are necessary for entering or performing a contract with you.
Examples of required identifiers include those that:
- Record data for maintaining user input during a session, such as supporting online shopping cart or chat functions
- Assist with authentication and security for a single session
- Enable multimedia playback
- Help us remember your Site preferences, such as language or country
- Enable the provision of information requested by you, including from third parties
If you have chosen to identify yourself to Bolster, we will place identifiers containing an encrypted, unique token on your device. These identifiers allow us to uniquely identify you when you are logged into the Sites, to enable you to use the Services and to process your online transactions and requests.
If you disable required identifiers, or set your browser to block or alert you about these identifiers, you may not be able to access the full functionality of our Sites and we may not be able to fulfill your requests.
FUNCTIONAL AND PERFORMANCE IDENTIFIERS
You make choices that make your experience with our Sites better for you and allow us to understand how our users move around, use and interact with our Sites.
As such, functional and performance identifiers help us remember your choices, improve your overall experience and enhance our services by giving us information about the effectiveness of our Sites, pages, operations and promotions.
For example, these identifiers:
- Help us remember your language or country preference
- Help us count visits and traffic sources so we can measure and improve website performance
- Can be used to remember customizations on the web pages
- Enable you to optimize your use of the Sites after logging in
We use our own technology (under our brand or an affiliated brand name) or third parties’ technology to track and analyze usage and volume statistical information from users to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.
If you do not allow these identifiers, we will not know when you have visited our Sites or be able to monitor their performance. Additionally, some or all of the enhanced functionality, personalization or customization of the Sites may not function properly.
TARGETING AND ADVERTISING IDENTIFIERS
Bolster uses identifiers delivered by us, or third parties, on your devices to collect information about you, such as your browsing history and which browsers you have used to visit our Sites, in order to generate user profiles and tailor relevant marketing. This can include showing you ads for Services that we think may interest you on any devices you may use and to track the performance of Bolster advertisements.
We share the information we collect or use with third parties to help create and deliver advertising personalized to you and your interests. Bolster re-associates this information with other information we collect about you. If Bolster is using one of its own products on our own Sites, then an identifier related to ads will appear on our Sites under the Bolster name (or one of our affiliated company names).
Bolster also may contract with third-party advertising networks that collect IP addresses and other information from web beacons or other technologies (see below) on our Sites, from emails and on third-party websites. Ad networks follow your online activities over time and across different sites or other online services by collecting Web Site Navigational Information through automated means, including through the use of any of the relevant technologies described above. These technologies recognize you across the different devices you use, such as desktop or laptop computers or mobile devices. Third parties use this information to provide advertisements about our Services tailored to your interests. You may see these advertisements on other websites or mobile applications on any of your devices. This process also helps us manage and track the effectiveness of our marketing efforts. Third parties, in conjunction with Bolster advertising partners, provide certain features on our Sites or display advertising based upon your web browsing activity, and use such identifiers to collect and store information, as discussed above in relation to functional and performance identifiers.
If you do not allow these identifiers, you will experience less targeted advertising.
WHO SETS IDENTIFIERS
Bolster, on our own or through service providers acting on our behalf, set identifiers on your devices.
Third parties also set identifiers on your devices that we do not control. For example, if you make use of embedded third-party content, the third-party outside content vendors use identifiers, and are responsible for informing you about, and collecting consent where applicable to make use of, such identifiers.
In addition, as noted above, we may work with one or more advertising networks that use identifiers to facilitate interest-based advertising on third-party websites.
YOUR CHOICES ABOUT IDENTIFIERS
With the exception of identifiers that are required and essential to operate our Sites and related content, for our European users, we will seek your consent before placing other important, but non-essential identifiers (as discussed above) on your devices.
Your identifier consent options include the following:
MODIFY YOUR BROWSER SETTINGS
You can modify your browser settings to control whether your computer or other device accepts or declines identifiers such as cookies or web storage tokens. These settings are generally available within your browser’s “Help”, “Tools” or “Edit” menus. If you choose to decline cookies, as noted above, you may not be able to use certain interactive features of our Sites and related content.
DELETE IDENTIFIERS FROM YOUR BROWSER
You can delete identifiers from your browser; however, that means that any settings or preferences managed by those identifiers will also be deleted and you may need to recreate them. Depending on your device, you may not be able to control tracking technologies through settings.
CONSENT OR OPT-OUT OF SPECIFIC IDENTIFIERS
When we send you emails, they might include a web beacon or similar technology (see below) that lets us know if you received or opened the email and whether you clicked on any of the links in the email. You can opt-out of marketing emails that use web beacons by clicking on the opt-out link contained within the email.
Learn more about how to manage privacy and storage settings for Flash cookies. Various browsers may also offer their own management tools for removing HTML5 local storage.
When you visit our Sites, only for our European users, we will ask for your consent to use non-essential identifiers through various means including displaying a consent banner or similar opt-in to our policies beyond continuing. While such users have the ability to opt-out of such identifiers through device- or browser-level settings, beyond asking for consent Bolster does not current offer additional options for managing identifiers for its Services. Whether a user is a European user is determined via IP address lookup.
To learn more about targeting and advertising identifiers, advertising networks and your ability to opt out of collection by certain third parties, please visit the opt-out pages of the Network Advertising Initiative and the Digital Advertising Alliance.
YOUR MOBILE DEVICE AND GEOGRAPHIC LOCATION
When you use our Services from a mobile device, in addition to obtaining usage data, we get information specific to your device that can benefit your use of and across the Services. For example, by using your IP address and geographic location, we will more easily enable your login across the Services or provide you content in your language preference. The personal information we access through a mobile device may be affected by your configuration.
THIRD-PARTY WEBSITES OR SERVICES
We receive data when you visit or use websites or services provided by others that include our ads or cookies (or similar technologies), such as when you share or like content or engage with us through social media.
HOW WE USE YOUR PERSONAL INFORMATION
How we use your personal information depends on the type of user you are, the personal information you provide to us, and which Services you use and how you use them. We use the personal information we have about you to provide you with and personalize your use of the Services, with the help of technology, automated decisions, and inferences, so that you can make the most out of the Services. We also use your personal information for marketing and sales communications.
OPERATING THE SERVICES
We use your personal information to provide and personalize the Services you have requested. If you are a customer, we use your email address, phone number, and device identifiers to authenticate your Bolster Account, allow you access and to keep them secure, as is necessary to perform our contract with you. We also use personal information to personalize our Services (such as language settings), help prevent abuse, spam, and fraud, and communicate with you about your use of the Services or related trainings, events or topics of interest we believe may be of interest to you. It is in our legitimate interests to provide you with more relevant and interesting content, and to keep our Services free of unauthorized users or unwanted content in order to provide a better experience for all of our users.
If you are an attendee at any of our events or co-sponsored events, we use your personal information for various reasons, including to grant you access, to evaluate attendance, and for marketing and analytics purposes. If you have otherwise provided your contact information for a business purpose, we will use it to discuss your interest in our Services, answer your questions or otherwise provide the information you request. It is in our legitimate interests to send you follow-up communications about our events, to analyze data about your attendance in order to understand the success of our events, and to provide you with appropriate responses and provide you with notices about our Services.
We use your information to contact you through mail, email, phone, text message, notices posted on our Sites, or other ways through our Services including pop-ups and push notifications, where permitted by applicable law. Bolster contacts you as a controller when you request information about Services or events, fill out a registration form through the Sites, or otherwise contact us. If you are located in Europe, barring an applicable legal exception, we will request your consent for marketing and sales communications by email and phone from Bolster concerning our Services.
Bolster will contact you to inform you about the availability and functionality of our Services, security, planned downtime, network updates or other service-related issues. We also send messages to benefit your use of the Services, including about events or suggestions about related resources, apps, products or services. We also use your personal information to notify you about changes to the terms and conditions of our Services, and to send you promotional messages from us or our third-party partners.
It is in our legitimate interests to provide you with appropriate responses and notices about our Services, either that you request or to inform you about features, functions, and other resources that might be of interest to you.
When the communication is a marketing, sales or non-transactional communication, you may manage your receipt of those messages by clicking on the “unsubscribe” link located on the bottom of the email or by replying to the email with a request to unsubscribe. If you are a customer, you cannot opt-out of receiving messages about Service-related issues, including security and legal notices.
MARKETING & ADVERTISING
We use certain information about our users for marketing, sales and advertising communications about our Services, invitations and other forms of engagement. We use your personal information and preferences, as well as usage data, information about materials you have downloaded or viewed through the Sites, automated systems and inferences, to build a profile about you. Using this data, we will place you into particular marketing segments in order to better understand your preferences, determine which Services and offers are best suited to your needs, provide you with the best contact person, and personalize the messages we send to you.
We may target ads to users both on and off our Services, including through emails, directly or through a variety of partners, and we measure the performance of these ads. We use the following personal information, by itself or in combination:
- Information you provide directly to us (e.g., name, contact information, organization information, interest in our Services, and marketing preferences);
- Information we receive from the Bolster partners in our partner program, including our ISVs, sponsors, and consultants
- Information we receive from our service providers
- Information inferred from data described above (e.g. using your marketing preferences to tailor what we send to you; using your job title to infer industry or the type of educational institution you work for; or using first names or pronoun usage to infer gender).
If you express interest in our Services, are a customer, inquire or register for an event or webinar, or otherwise contact us, we will show you ads on or off our Sites, including on social media, other web pages or through email, of Services we believe might be of interest to you. If you take an action on these ads (such as signing up for our Services), your action will be associated with your name and viewable by others, including our third-party advertisers if applicable. It is in our legitimate interests to provide you with these more relevant and interesting marketing messages and advertisements.
INFORMATION TO THIRD-PARTIES
However, if you view or click on an ad for us on or off our Sites, our third-party advertising providers and networks will get notified that someone visited the page that displayed the ad, and they may determine it is you through technology (e.g. through cookies). We (in conjunction with these advertising providers) will analyze this information to assess the effectiveness of the advertising campaign. Similarly, if you contact a Bolster partner through our Services, the consultant will receive a notification that someone contacted them through or due to the Services.
DEVELOPMENT AND RESEARCH
We use your personal information to conduct service and business development, to enhance the user experience, to conduct research, and to distribute and analyze survey responses. It is in our legitimate interests to process personal data for these purposes, in order to understand and analyze any issues with our Services in order to improve them.
SERVICE AND BUSINESS DEVELOPMENT
Our Services are dynamic and we are always looking for ways to offer you the best user experience. We use data about the use and users of our Services, as well as communications and other feedback, to conduct research and development, by ourselves or in conjunction with our service providers as applicable, to improve or offer you new services, provide you with a more user-friendly and personalized experience, drive engagement with our Services, and sign up new customers.
We seek to use our technology to improve the performance and success of nonprofit organizations and care providers. We use personal information available to us to research trends and determine the best methods of implementation of our Services to ensure success. In some cases, we work with trusted service providers to conduct this research, and we mandate they adhere to procedures that protect your privacy. We publish our insights, presented as aggregated data that does not identify you, unless we have your explicit permission to identify you.
Surveys are conducted by us and our partners, such as our co-sponsors, through our Services. Participation in the surveys is voluntary, and you have choices about what information you provide.
We use your personal information (including your communications) to provide you help and technical support, such as investigating, responding to, and resolving complaints and issues with the Services (like bugs, spam, and availability issues). This is so we can provide the Services according to our contract with you.
We use your personal information to produce, analyze, and share aggregated insights without identifying you. For example, we use your data to generate statistics about the use of our Services, including the types of customers we have and their preferences, our most popular Services and their effectiveness, who attends our events, the effectiveness of ad campaigns, or for any other business purpose. It is in our legitimate interests to aggregate information and use it in a non-personalized way to improve our offerings.
We use your personal information (including your communications) if we believe it’s necessary for the security of our Services. It is in our legitimate interests to provide safe and secure services to all of our users.
EXERCISING OUR RIGHTS
COMPLYING WITH OBLIGATIONS
We use your personal information when necessary to comply with our legal obligations. For example, we use it to carry out fraud prevention checks or comply with other legal or regulatory requirements.
HOW WE SHARE YOUR PERSONAL INFORMATION
We share your personal information with other parties as needed to provide and enhance the Services, as requested by you, or as required by law, as described further below.
If you are a customer, we share your personal information to provide you with the secure and reliable Services you have requested.
If you are an attendee, we share your personal information with our event or webinar co-sponsors, if applicable or as requested by you, to ensure access, participation, and that you obtain the requested information before, during, and after the event. We will also use it to follow up with you after the event, to analyze the event, and for marketing purposes.
If you have contacted us, filled out a webform, or requested information from us or our partners, we share your personal information to provide you with the Services or information requested. We also share personal information you provide through your engagement with our Services off our Sites, including through identifiers placed on our third-party advertising providers’ websites. We share this personal information with our third-party advertising partners for analysis.
Depending on the Service you select, we may ask for permission to share your relevant personal information before you use such Service. For example, if you request information about or from our co-sponsor for an event, we may request that you opt-in to communications through a separate, applicable form.
In some instances, we will share personal information about you through stories or content we publish on our website, such as Customer Testimonials. This information will be public to users of the particular Site, and we will obtain your permission before publishing the content if it will include personal information about you. If you have initially approved our sharing your personal story or data publicly in one format including, but not limited to, a Bolster video, webinar, landing page, e-book, article, social media post or Customer Testimony, we reserve the right to re-use, re-publish, or edit your story for the blog for marketing purposes without asking you a second time.
OUR SERVICE PROVIDERS
We share personal information about our customers and event attendees with our service providers so that they are able to provide services on our behalf or ensure the quality of information provided. For example, we use service providers to process billing, secure payments, fulfill orders, optimize services, prevent and detect fraud, serve online behavioral advertising, send newsletters and marketing messages, support email and messaging services, analyze information, perform maintenance or audits, provide consulting services, evaluate the effectiveness of our marketing, and perform research and development. They will have only the amount of access to your personal information as is reasonably necessary to perform the tasks on our behalf and are contractually obligated not to disclose or use it for other purposes.
As stated above, from time to time, we engage a number of different types of Bolster partners, including consulting partners, ISVs, and sponsors, who also serve the nonprofit and education communities. If a user expresses an interest in a service provided by our partner, or that we provide in conjunction with a partner (such as a co-sponsored event), we will share your personal information with that partner to enable your use of or access to those services, or otherwise communicate with that partner. We do not control our partners’ use of the personal information we share with them, and their privacy policies will govern. If you do not wish for your information to be shared in this manner, you may choose to refrain from expressing interest in or using our partner’s service.
REQUIRED BY LAW
We share your personal information with law enforcement agencies, courts, other government authorities or other third parties that have a legal reason to obtain your information where we have a good faith belief that disclosure is necessary to comply with a legal or regulatory obligation (such as our nonprofit status or to comply with a subpoena), enforce our agreements with you, protect our rights or the rights or safety of any third party, or protect the security or integrity of our Service.
IN THE CONTEXT OF A TRANSACTION
This section discusses certain rights and information for users located in the EU, particularly those users whose personal information is governed by the European Union’s General Data Protection Regulation (“GDPR”).
RIGHTS TO YOUR PERSONAL DATA
In addition to accessing your personal data from within the Services, users located in the EU have certain rights and protections about the collection, sharing, and use of your personal data including as follows:
- Right to Access Your Data: You can ask us for a copy of the personal information we have about you.
- Right to Rectification/Correction: In addition to modifying your data from within your Bolster Account, you can also ask us to change, correct, or update your data in certain cases, especially if it is inaccurate.
- Right to Erasure/Right to be Forgotten: You can ask us to stop using or erase all or some of your personal information (if we have no legal right to keep using it).
- Right to Data Portability: You can ask us for a copy of the personal information you provided to us in a commonly used and machine-readable format.
- Right to Object or Restrict Processing: You can object to or ask us to restrict processing under certain circumstances
For users located in the EU, please email us at email@example.com to make a detailed request regarding these rights. If we determine that your request is in accordance with applicable laws, we will accommodate it to the best of our ability. We will also handle your request or contact you within the time required by law. If you are located in the EU, you may also contact our DPO or your local data protection regulator.
LAWFUL BASES FOR PROCESSING
We only collect and process your personal information when we have a lawful basis for it. These lawful bases can include: (a) contract (where it is necessary for the performance of a contact with you (e.g. to deliver the Services you have requested)); (b) consent (where you have given your consent such as through opting in); and (c) our other legitimate interests. We describe our lawful bases for processing personal information earlier.
When your consent is the basis for us to process your personal information, you may revoke your consent at any time. Where we rely on our legitimate interests, you have a right to object. If you have questions about the lawful bases upon which we collect and process your personal information, please contact our Data Protection Officer at firstname.lastname@example.org.
ACCESSING OR AMENDING YOUR DATA FROM WITHIN THE SERVICES
If you are a customer, you may update or change the personal information you have input into your user profile by editing your user or organization record from within your Bolster Account. You can also remove other interactive content you have shared with the Services, such as through social media, by deleting or removing it from within that third-party service. For technical support, to update billing information or discontinue your account and have information you maintained in the Services returned to you, please email us at email@example.com.
BOLSTER ACCOUNT CLOSURE
If you are a customer and decide to close your Bolster Account or allow it to expire, our retention policies are detailed in separate agreements provided to you at the time of Account creation. Please email us at firstname.lastname@example.org if you need another copy of these agreements. We retain your personal information after you close your Bolster Account as detailed in your separate agreement with us or as long as it is reasonably necessary for compliance with our legal obligations, regulatory requirements, or security purposes, to prevent or detect fraud or abuse, enforce our contractual obligations with you, fulfill your request to unsubscribe from messages, or if recovery services had been enabled.
Please note that although your Bolster Account may be closed or deleted, your posts, documents and other information shared with others, such as exchanged messages, will generally still be available to others if they have been downloaded or are located in another customer’s inbox or cloud service. We do not control data that other users have copied from the Services.
We implement physical, technical and organizational security safeguards to protect your personal information we control and process through the Services. We regularly monitor our systems for possible vulnerabilities to provide on-going availability, integrity and confidentiality of your personal information. However, no information system can be 100% secure.
INTERNATIONAL DATA TRANSFERS
Our Sites are accessible globally and may process personal information both inside and outside of the United States. Your personal information will be transferred to, stored and processed in countries that have different laws than your home country, and are potentially less protective. We utilize legally-provided mechanisms including EU model clauses to lawfully transfer data across borders and ensure an adequate level of protection for the rights of users located in the EU based on the adequacy of the receiving country’s data protection laws. For more information on such mechanisms or to obtain a copy of such safeguards, please contact us at the contact information set forth below.
CHILDREN AND OUR SERVICES
Our Services are not directed to children, and you may not use our Services if you are under the age of 18 unless we have a separate agreement with you to do so.
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If you would like to contact us, please first email us at email@example.com.
If you are located in the EU, you may also contact our Data Protection Officer at firstname.lastname@example.org. If you are located in the EU and believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of your country of residence