Last updated: May 27, 2020
This policy explains how Delta Gamma LLC, doing business as blucheq (“we”), use the personal data we collect from you when you use our website or services through email, telephone, online chat or other communication tools.
We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and we comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at privacyshield@blucheq.com. We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you. If your complaint remains unresolved, you have the right to invoke binding arbitration under certain conditions.
We collect the following types of personal data, either directly or using contracted data processors:
- Name
- Business name
- Business website URL
- Business contact information (email address, phone number, and mailing address)
- Payment information
You directly provide us with most of the data we collect when you sign up, use our services, and voluntarily share it through chat, email, or telephone support channels.
We may also collect your business contact information from your website or other websites to contact you to pursue legitimate interests of supporting your compliance efforts. If this is the case, we provide you the option to opt out of future communications from us and store your data in our opt-out list to honor your request.
We use your data to market our services, track our sales, process your payments, manage your account, and provide support. If you have elected to opt out of communications from us, we store your data in our opt-out list to honor your request.
We make your data available to your representative in the European Union (Global Data Protection OÜ) at all times and we use the following data processors to carry out the activities mentioned above:
- Airtable (Formagrid, Inc.): Account management and opt-out list
- Chargebee (Chargebee, Inc): Account management
- GSuite by Google (Google, LLC): Customer support
- HubSpot (HubSpot, Inc.): Sales tracking and customer support
- Slack (Slack Technologies, Inc. and Slack Technologies Limited): Account management
- Stacker (Stacker Software Ltd): Account management
- Stripe (Stripe, Inc.): Payment processing
- Typeform (Typeform US LLC): Account management and marketing
We do not share your data with any other party unless required in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. If blucheq is acquired by or merged with another company, we may share your personal data with that company. We accept liability in cases of onward transfers to third parties.
We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of your personal data in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite best efforts.
Additionally, our data processors, affiliates, and partners may collect personal data from you that is outside of our control and should be contacted separately in accordance with their privacy policies.
We process data using Airtable and Typeform, with servers located in the United States. Data at rest is encrypted using AES-256 and the transmission of information is protected using TLS encryption. You can read more about Airtable’s security practices at https://airtable.com/security and Typeform’s security practices at https://help.typeform.com/hc/en-us/articles/360029259552-Security-at-Typeform.
Our data processors Chargebee Inc., Google LLC, Hubspot Inc., Slack Technologies Inc. and Stripe Inc. are participants of the EU-US Privacy Shield with a commitment to take reasonable and appropriate measures to protect data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal data.
Every user of our website or services is entitled to the following rights with respect to their personal data:
- Access: You have the right to request copies of your personal data.
- Rectification: You have the right to request we correct any information you believe is inaccurate.
- Erasure: You have the right to request we erase your personal data other than those we are required or permitted by law.
- Restrict processing: You have the right to request we restrict the processing of your personal data where it doesn’t inhibit our own compliance with laws and regulations.
- Object to processing: You have the right to object to our processing of your personal data where it doesn’t inhibit our own compliance with laws and regulations.
- Data portability: You have the right to request we transfer data we have collected to you or to another organization.
You may exercise any of your rights by contacting us at privacy@blucheq.com. We will respond to you as soon as possible, and in any instance, within 30 calendar days.
Additionally, you may call us at +1 844 REP-GDPR (737-4377), or write to us at 90 Church Street #761, New York, NY 10008.
If you are a national data protection authority in the EU or a resident of the EEA, in addition to the ability to contact us directly at privacy@blucheq.com, you may contact us through our EU representative by emailing 15032463@article27rep.eu.
We send you information about products and services of ours as well as those of our affiliates and partners, listed below:
- CCPA Toll Free
- CRC LEX
- CookiePro by OneTrust
- CoverWallet by Aon
- Global Data Protection
- GSuite by Google
- iubenda
- Simple Analytics
- termly.io
- Woodpecker
You have the right at any time to opt out from receiving marketing messages by following the instructions in the marketing email you receive from us or replying to the sender with your request to opt out.
Cookies are text files placed on your computer to collect information about you and your online behavior. Web beacons are files, such as small images placed on websites, that can collect personal information about you, such as your IP address. We do not use any cookies or web beacons that collect personal data on our website or services.
We do not sell your data, nor do we use any cookies or trackers by parties that advertise to you across websites you visit.
We regularly review our policy and publish any updates on this webpage. This privacy policy was last updated May 27, 2020.
If you have any questions about our privacy policy, please contact us at privacy@blucheq.com or 90 Church Street #761, New York, NY 10008.
