The Betterchips Consulting Corp. (“COMPANY”) employees and partners are a team of professional consultants who understand the importance, value, and sensitivity of data. This Privacy Policy (“POLICY”) is intended to provide you with an explanation of what information COMPANY collects, and how that information is processed, stored and shared, both digitally and in physical format. All visitors to any of COMPANY’s sites or publications are invited to read this POLICY to gain a better understanding of COMPANY’s use of your information and its commitment to ensuring its protection.

For subscribers to COMPANY SERVICES, this POLICY should be read in conjunction with the Master Services Agreement (“MSA”), incorporated herein by reference. Unless otherwise defined in this POLICY, the terms defined within the MSA have the same meaning in all documents.

This POLICY is organized into easy-to-follow sections to help make finding the information you are looking for easier.

About Betterchips

In this POLICY, the words “COMPANY” and “Betterchips” refer to Betterchips Consulting Corp. and its employees, consultants, subcontractors and affiliates. COMPANY is a globally recognized consulting firm built upon an ecosystem of trusted professionals in virtually all areas of computing technology. The unique ability to combine business, legal, and technological expertise gives COMPANY a strategic insight into many issues where others can’t navigate.

COMPANY collects information about visitors to COMPANY’s websites in order to facilitate a functional and professional relationship, and to better serve you by tailoring that experience to your needs. COMPANY’s websites include:

• COMPANY’s password-protected websites, including those that interact with COMPANY’s SERVICES
• Betterchips.com website
• various COMPANY blogs, social media profiles, event pages, and other websites

These individual sites are collectively referred to as the “SITES” and may also include any other publicly accessible website not mentioned above where this POLICY is posted.

For visitors to and users of COMPANY SITES, this POLICY should be read in conjunction with the Terms of Service (“TOS”), incorporated herein by reference.

Data Processing and Handling

The specific information COMPANY collects from or about you depends on the nature of your relationship with COMPANY or your interaction with COMPANY’s SITES and SERVICES. The information COMPANY collects may include both PERSONAL DATA and OTHER INFORMATION, as detailed below.

PERSONAL DATA. For the purposes of this POLICY, “PERSONAL DATA” is information from which you could be identified, directly or indirectly. PERSONAL DATA may include one or more of the following:

• contact and business information (title, name, email address);
• payment information;
• account information;
• social media data;
• information from third-parties;
• other unique identifying information.

OTHER INFORMATION. For the purposes of this POLICY, “OTHER INFORMATION” is any information that does not independently reveal your specific identity or does not directly relate to an identifiable individual. Examples include

• IP address(es);
• device information;
• browser type and metadata;
• time and date of requests;
• login activity;
• cookies.

Gathering this information aids COMPANY in ensuring the proper operation of COMPANY’s SITES and SERVICES and providing a high level of availability and usability.

Cookies and Related Technologies

Cookies are small text files containing information unique to your account or browser that may be read from your device through usage of COMPANY SITES and/or SERVICES. COMPANY uses cookies and related technologies to track activity throughout the use of COMPANY’s SITES and SERVICES. COMPANY uses cookies to collect information about the way that you use the SITES or SERVICES, support the features and functionality of the SITES and SERVICES, and personalize the experience of the SITES and SERVICES.

You can manage your browser’s cookies and related technology preferences through your browser settings. You can also disable or block the use of cookies and similar technologies that track your activities. Please note, however, that use of COMPANY’s PORTAL requires cookies to be enabled in your browser.

COMPANY may combine the collected PERSONAL DATA and OTHER INFORMATION into a more comprehensive dataset to work with, such as identifying your approximate geographical location from your IP address and combining website browsing data, allowing for a greater personalized experience. If COMPANY combines PERSONAL DATA with any OTHER INFORMATION, COMPANY will treat the combined information as PERSONAL DATA.

COMPANY will never collect PERSONAL DATA that isn’t necessary for the intended purpose of processing that information. You are also not required to share the PERSONAL DATA that COMPANY requests. However, if you choose not to share such information, it may hinder your ability to use COMPANY’s SITES and SERVICES.

The Betterchips Websites

COMPANY maintains control of the data provided to, collected by or for, or processed in connection to the COMPANY SITES, as defined in this POLICY.

What Data is Collected and How it is Collected

Information You Provide

COMPANY collects information about you through COMPANY’s SITES, online forms, online chat and email, for example when you request a demo or contact COMPANY via COMPANY’s SITES or as directed in the CONTACT US section below.

When you communicate with COMPANY, all communications received will be stored unless otherwise requested by you at the time of that communication. If you are submitting information on behalf of another individual, you are responsible for obtaining appropriate consent, including consent to share and transfer any PERSONAL DATA across borders.

Information Collected Automatically

Log data. COMPANY’s servers automatically collect information standard to most Internet technology services when you access or use COMPANY’s SITES. This information is recorded as access logs. These logs may include any combination of IP address, browser and related metadata, the date and time of the request, language preferences cookies (if enabled), and usage data.

Device Information. COMPANY collects data about the devices that access the SITES, which may include the device’s type, settings, application IDs, and other unique identifiers. Whether COMPANY collects any or all of this information will depend on the type of device used, it’s specific configuration, and your response to prompts for information.

Location Information. COMPANY receives data that assists COMPANY in tracking of approximate device locations. This data may be provided directly from you or may originate from other third-parties. COMPANY may, for example, determine that device’s approximate location using the IP address reported by your browser or device while accessing the SITES. COMPANY may also collect information from devices in accordance with the consent process provided by your device.

Third-parties. COMPANY may automatically collect information by way of data collection tools and website tracking technologies such as cookies, web beacons or tracking pixels, widgets, buttons or other similar technologies. COMPANY may also permit certain third-parties to use similar technology for the same purpose. These tracing methods can be disabled by you through your device and/or browser configuration.

How We Use That Data

COMPANY may use the information collected for the following purposes:

• To conduct ordinary business operations such as sales, marketing, support, research, development, education, training and recruiting;
• To facilitate corporate reporting and management;
• To improve the operation of COMPANY’s SITES and SERVICES;
• To maintain a safe and trusted environment for customers, SITES visitors, COMPANY employees and members of the public; and
• To conduct other similar uses pertaining to the COMPANY SITES.

How We Share That Data

• Sharing with COMPANY Affiliates. COMPANY may share your PERSONAL DATA with COMPANY’s affiliated entities for the purposes described in this POLICY. As part of COMPANY, COMPANY’s entities and COMPANY affiliates are subject to this POLICY, and COMPANY’s internal privacy policies and data protection requirements.
• Compliance with Legal Requirements. COMPANY may be required to disclose your PERSONAL DATA to comply with applicable laws or requests. Such situations may include laws outside of your country of residence, court orders, regulations, government and law enforcement requests, national security requirements, or other law enforcement requirements. Additionally, if COMPANY reasonably believes that it is necessary or appropriate, COMPANY reserves the right to use or disclose your PERSONAL DATA to allow COMPANY to protect COMPANY’s legal rights or property, to protect the safety of COMPANY employees, users or others, and to pursue available claims or remedies, to the extent allowed by applicable law. This includes exchanging information with companies and organizations for the purposes of fraud detection.
• Corporate transactions. Circumstances may arise where COMPANY buys or sell assets or businesses as part of a sale, merger or change in control of COMPANY or be a part of, or subject to, some other type of voluntary or involuntary reorganization or restructuring. In such transactions, COMPANY may disclose or transfer your PERSONAL DATA as a business asset, in accordance with this POLICY, to prospective or actual purchasers or receive your PERSONAL DATA from sellers or counterparties. Any entity which buys COMPANY, in part or wholly, will have the right to continue to use the information COMPANY has collected and stored, but only in accordance with this POLICY.
• Sharing data with third-parties. COMPANY retains third-party service providers to manage or support certain aspects of COMPANY’s business. These third-party service providers may be located globally and may provide services to COMPANY such as communication services, website hosting, advertising and marketing services, data analysis, data hosting, address validation services, providing information technology infrastructure, email delivery, credit card processing, auditing and other similar services. COMPANY’s third-party service providers are contractually bound to safeguard any PERSONAL DATA they receive from COMPANY and they are prohibited from using such PERSONAL DATA for any purpose other than to perform the services as requested by COMPANY.

Marketing Activities

COMPANY maintains control of any data collected by, collected for, provided to, or processed in association with certain “MARKETING ACTIVITIES”. These may include email communications, webinars, conferences, events or other similar activities. COMPANY, and the third-party service providers contracted by COMPANY, may collect information in the following ways:

What Data is Collected and How it is Collected

Information You Provide

COMPANY may collect the following information from you:

• Online – directly submitted to COMPANY through COMPANY’s SITES, for example when you register for a MARKETING ACTIVITY or SERVICE, subscribe to COMPANY’s email newsletter, request user guides or technical documentation or download content (such as case studies or whitepapers).
• Offline – such as when you attend COMPANY’s events in person or during phone calls with COMPANY employees, partners, or affiliates.

Information Acquired from a third-party

COMPANY may receive additional information about you from third-parties, such as partners, social media platforms, lead generation services or public databases. COMPANY may receive this information for any one of the following purposes:

• To expand or enhance the offers and SERVICES that COMPANY can offer to you;
• To improve the quality or personalization of COMPANY’s SERVICES to you;
• To improve the relevance of marketing COMPANY may employ;
• To help COMPANY correct or supplement COMPANY’s records; and
• To verify your identification in instances of suspected fraud or identity theft.

COMPANY only accepts information from third-parties able to demonstrate that all necessary consent has been provided to share such information with COMPANY.

How We Use that Data

Information collected through COMPANY’s MARKETING ACTIVITIES may be used in the same way COMPANY uses information collected through COMPANY’S Sites. Additionally, this information may also be used for the following purposes:

• To personalize marketing and SERVICES recommendations to your interests;
• To contact you with business, marketing and sales communications that you have agreed to receive, or to notify you of upcoming events;
• To update and improve COMPANY SERVICES;
• To conduct market research;
• To facilitate corporate reporting and management;
• To verify your identity, if necessary for payment, registration or similar circumstances; and
• To conduct other similar uses related to COMPANY’s MARKETING ACTIVITIES.

How We Share that Data

COMPANY may share information collected through COMPANY’s MARKETING ACTIVITIES in the same way COMPANY shares information collected through COMPANY’s SITES. Additionally, this information may be shared for the following purposes:

• Communicating with you regarding a COMPANY Event. COMPANY or COMPANY’s partners may communicate with you about events promoted, hosted or co-sponsored by COMPANY or COMPANY’s partner(s). Such communications may include information about event content or logistics, payment requirements, instructions or other details, updates, changes to, or cancellation of the event, follow-up regarding registration, post-event follow-up, and event-related SERVICES provided by COMPANY.
  After a COMPANY Event, COMPANY may share information about you or your attendance with designated event sponsors, partners, or other third-parties for event-related communications.
  Information provided directly to a COMPANY partner or conference sponsor during events or event-related communications is subject to that party’s own privacy policies. You should review their privacy policies to learn how they use information they collect.
  Events may also include additional privacy-related policies or terms unique to that event, in which case those policies and/or terms will be provided to you before or at the time of the event registration, or at the commencement of the event.
• Engaging in advertising. COMPANY may provide personalized promotional offers for SERVICES that may interest you, in accordance with your privacy preferences regarding COMPANY SERVICES, COMPANY communications, and other selected partner websites. For example, an advertisement for SERVICES that you have recently viewed on COMPANY SITES may be displayed on a partner site. COMPANY may also partner or contract with third-parties to display advertising for COMPANY SERVICES on websites owned by those or other third-parties. Any of these may be achieved by the use of cookies, or by sharing your PERSONAL DATA as described in this POLICY.

Customer Relationship

Through our existing customer relationships, COMPANY provides training and technical support. Educational services and marketing services may also be provided to certain partners and prospective customers through secure, password-protected portals, or other industry-approved methods of secure transmission. In these relationships, where the data is still controlled by you (the customer, partner, prospective customer, or visitor), COMPANY is a processor. COMPANY collects, processes and stores information throughout these processes, as described herein:

What Data is Collected and How it is Collected

Information Customers and Certain Users Provide Directly Through Password Protected Portals

COMPANY collects data as registration details from you when an account is created, and as that account is maintained. COMPANY will also collect the data that you share with COMPANY through your use of provided SERVICES, according to your organization’s specified preferences within COMPANY SERVICES, SITES or PORTAL, or configuration of COMPANY SERVICES.

COMPANY also collects data through written or verbal communications, and requests submitted through COMPANY’s SITES and PORTAL. As part of the SERVICES support process, customers must consent to the processing and transfer by COMPANY’s employees and partners of the data they submit, including any of the customer’s end user data they may submit in the support process. When submitting data on behalf of a third-party, it is the customer’s responsibility to ensure that they have permission to do so.

Information Collected Automatically

COMPANY may automatically collect information through COMPANY’s SERVICES in the same way COMPANY automatically collects information through COMPANY’s SITES.

Anonymized, Aggregated Data

In addition to the information provided to COMPANY directly or automatically, COMPANY also collects anonymous and aggregated information about how COMPANY’s SERVICES are used, for the improvement of COMPANY’s SITES and SERVICES. As part of COMPANY’s operations steps may also be taken anonymize or pseudonymize your PERSONAL DATA for regulatory compliance, market analysis and other COMPANY business purposes.

How We Use that Data

COMPANY collects and uses customer information as necessary for the performance of COMPANY SERVICES and/or contracts to you as a customer, and in accordance with applicable contract terms.

Use of Account Generated Data.

COMPANY uses account generated data in order to facilitate and promote COMPANY’s legitimate interests in operating the COMPANY SITES. COMPANY may use information collected through COMPANY’s customer relationships in the same way COMPANY uses information collected through COMPANY’s SITES, MARKETING ACTIVITIES, as well as for the following purposes:

• To prevent fraudulent activities, such as fraudulent purchases;
• To review and respond to requests or feedback that you may provide to us;
• To verify your identity if required to fulfill or provide access to SERVICES;
• To periodically review quality of SERVICES or to ensure appropriate quality of SERVICES is delivered;
• To monitor use of SERVICES to ensure compliance with COMPANY’s Master Services Agreement;
• To personalize offerings and advertisements of SERVICES to you;
• To provide notification of SERVICE or SITE enhancements or changes;
• To process credit card transactions, potentially using third-party processors, for authorized purchases of SERVICES, training, or events;
• To monitor calls for training and/or SERVICE quality; and
• To conduct other similar uses pertaining to COMPANY’s relationships with COMPANY’s customers.

How We Share that Data

COMPANY may share information collected through COMPANY’s customer relationships in the same way COMPANY shares information collected through COMPANY’s SITES, as well as for the following purposes: Sharing with COMPANY partners. COMPANY may engage third-party technology and implementation partners for joint sales or promotion of SERVICES. COMPANY will always the partners involved in these situations. COMPANY contracts with COMPANY’s partners for these activities and COMPANY’s partners may have access to your PERSONAL DATA. Either COMPANY or COMPANY’s partners may use that information to provide you with sales or product promotion information. Any such use by COMPANY partners is subject to such partners’ own privacy policies.

Processing of Data

COMPANY will only collect and process your PERSONAL DATA in the ways described in this POLICY when COMPANY has sufficient reason in doing so.

Reasons for COMPANY to process PERSONAL DATA include:

• Provided Consent
  Certain PERSONAL DATA is processed only based on the consent you provide to COMPANY at the time of submission. Where COMPANY relies on your consent, you have the right to withdraw or decline your consent at any time.
• Contract Fulfillment
  When information is processed for the purpose of fulfilling a contracted SERVICE, you are able to terminate the contract by following the requirements defined within that contract and request that your PERSONAL DATA be returned to you and/or deleted.
• Compliance with Applicable Laws
  Fulfillment of some SERVICES may require COMPANY to request you to provide PERSONAL DATA to comply with a legal requirement necessary in the performance of a contract with you. In such situations, COMPANY will make clear this requirement and advise you whether the provision of your PERSONAL DATA is mandatory or not, and of any possible consequences of not providing that information.
• Legitimate interests of COMPANY or any third-parties.
  Legitimate interests in which COMPANY may process PERSONAL DATA include enabling COMPANY to conduct audits, mergers, acquisitions, reporting, and other such internal business services, and for the improvement of COMPANY’s SERVICES. PERSONAL DATA will only be processed on these grounds when doing so does not outweigh your rights. Where COMPANY relies on legitimate interests, you have the right to object at any time.

How PERSONAL DATA is Protected

COMPANY values the importance of information, and the need to keep PERSONAL DATA secure. COMPANY has implemented and maintains technical, administrative and physical security measures designed to safeguard PERSONAL DATA from unauthorized access, alteration, misuse, disclosure, accidental loss or destruction.

COMPANY regularly reviews COMPANY’s security procedures to ensure that the confidentiality, integrity, availability and resilience of all PERSONAL DATA both online and offline are maintained. The specific security procedures and measures utilized vary based on the sensitivity of the data that COMPANY collects, processes and stores as well as the current state of technology. At any time, these measures may include data encryption, firewalls, physical access controls and/or data access authorization controls. COMPANY takes steps to regularly monitor COMPANY’s systems for vulnerabilities and to ensure that data is only shared to parties who need to know it.

However, no website or Internet transmission is entirely secure. While COMPANY is committed to taking all appropriate and reasonable actions necessary to safeguard your data, COMPANY cannot absolutely guarantee against the occurrence of unauthorized access, hacking, data loss or a data breach, and COMPANY cannot warrant the security of any PERSONAL DATA that you provide to COMPANY. You are responsible for maintaining the privacy and security of any password(s) and account registration information used with or provided to COMPANY, and verifying that the PERSONAL DATA provided to COMPANY remains accurate and current. COMPANY is not responsible for protecting any PERSONAL DATA that COMPANY shares with a third-party in any manner or for any purpose that you have authorized.

COMPANY requires that COMPANY’s partners and third-party service providers agree to maintain the confidentiality of the PERSONAL DATA shared with them and to only process that PERSONAL DATA to perform their obligations based on the agreements COMPANY has in place with them. COMPANY internal policies ensure that such parties are required under contract to maintain privacy and security protections which are at least as consistent with COMPANY’s own policies and practices.

Retention of PERSONAL DATA

COMPANY will only retain your PERSONAL DATA for as long as is required to fulfill the purposes outlined in this POLICY unless a longer retention period is required by law, permitted by law, or unless activities pursuant to the exercise of your rights results in the deletion of the PERSONAL DATA before that time. COMPANY may however retain cached or archival copies of PERSONAL DATA provided to COMPANY in the course of normal business operations or disaster recovery measures. The deletion of your PERSONAL DATA and other use of COMPANY’s SITES may result in the deletion and/or de-identification of OTHER INFORMATION that is retained by COMPANY.

Exclusions

This POLICY applies only to your relationship with COMPANY through your use of COMPANY’s SITES, SERVICES, training, communications, marketing and advertising activities and events.

While using COMPANY’s SERVICES, COMPANY may provide links to other websites which directly provide information relevant to your use of COMPANY SERVICES. COMPANY will provide notice of when COMPANY does this. Any interactions you have with these other websites are beyond the control of COMPANY. The SITES may provide links to websites and access to third-party managed content, products and/or services, including users, partners, advertisers, and sponsors of the SITES. All such third-party websites, content, products and/or services are governed by their respective terms and conditions.

Your Privacy Rights

COMPANY provides you with options to exercise certain controls and choices regarding COMPANY’s collection, use, and sharing of your PERSONAL DATA.

Please note that, if you do not allow COMPANY to collect your PERSONAL DATA from you, COMPANY may not be able to deliver certain SERVICES to you, and some of the COMPANY SERVICES may not be properly tailored to your preferences.

Your Options

In accordance with applicable law, you may be entitled to exercise your rights as follows:

• Account settings. Your profile, account information, and any related PERSONAL DATA may be updated by you at any time to ensure that PERSONAL DATA is up to date or delete inaccuracies.
• Devices and browsers. Some of COMPANY’s SERVICES may use your device’s location information, including but not limited to your devices real time location, in the case of mobile phone or other location-enabled mobile devices. You may adjust the settings of your device at any time to control the sharing of your device’s location with COMPANY.
• Communications from COMPANY. COMPANY may use your PERSONAL DATA to communicate with you via email, including sending you transactional and/or marketing emails. COMPANY provides options for you to opt out of marketing communications, however not all communications you may receive from COMPANY are considered marketing communications. Such communications could be related to transactions, file downloads, system updates and other support-related information, security alerts, events for which you have registered, disclosures in compliance with legal requirements, and (where permitted by law) quality assurance survey requests. Such emails are considered transactional and are not subject to general opt-out requirements. Some additional communications you may receive from COMPANY’s partners may also not be subject to general-opt out, including product alerts, updates, and other notices related to partner status. You request COMPANY stops sending you marketing emails by following the instructions included within COMPANY’s marketing emails. Communications related to COMPANY’s PORTAL may be personalized through the management of your account profile within the PORTAL. If you have any issues unsubscribing, you may contact COMPANY as directed in the CONTACT US section below.
• Cookies. Most desktop, mobile, and tablet web browsers provide options that allow you to control or reject cookies or to alert you when a cookie is about to be placed on your computer, tablet or mobile device. While you are not required to accept cookies, if they are blocked or rejected, you may not have access to all features or functionalities available through COMPANY’s SERVICES. Please refer to the Cookies and Related Technologies section of this POLICY for more information.

Updates to Published Policies and Contact Information

Updates to this POLICY

On occasion, COMPANY may change this POLICY to accommodate regulatory requirements, industry practices, new technologies, or to reflect changes in how COMPANY processes information. Any changes to this POLICY will be considered effective when COMPANY posts the revised POLICY on this website unless otherwise directly communicated. The “LAST UPDATED” section at the top of this POLICY indicates when this POLICY was last revised and serves as notice of the update. Your use of the COMPANY SITES, content, or SERVICES provided following these changes is your acceptance of the revised POLICY.

Contact Us

If you believe your PERSONAL DATA has been used in a way that is inconsistent with this POLICY or preferences which you have provided, or if you have questions related to this POLICY, please contact COMPANY’s Compliance Officer at the address below or by emailing: compliance@betterchips.com

Written inquiries may be addressed to COMPANY’s Compliance Officer at: