Privacy Policy
Last modified: 07.26.2022
Be Original Americas, Inc. (“BEOA”, “we”, “us”, “our”) take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.
Please read this Privacy Policy and Cookie Policy (“Privacy Policy”) carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, including this Privacy Policy, your choice is not to use our website.
This Privacy Policy does not apply to information collected by us offline.
1. Personal Information We Collect About You.
Personal information is any information relating to an identified or identifiable individual. We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
2. How Your Personal Information is Collected.
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. We collect data and process data when you register online, place an order for any of our services, voluntarily complete a customer survey or provide feedback on any of our message boards, on our social media accounts or via email. However, we may also collect information:
From publicly accessible sources;
Directly from a third party (e.g., credit reporting agencies,);
From a third party with your consent (e.g., your bank);
From cookies, web beacons or other tools on our website (see below “What are Cookies and Similar Technologies and How Do We Use Them?”); and
Via our IT systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.
From our payment processors, electronic data storage providers, and other service providers that help us market our services and deliver our services to you.
3. How and Why We Use Your Personal Information.
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:
To comply with our legal and regulatory obligations;
To manage your account;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
4. Who We Share Your Personal Information With. We routinely share personal information with:
Third-party service providers we use to help deliver our services to you and/or who we use to help us run BEOA, operate our website and/or deliver information or other services to you, such as marketing agencies or website hosts, survey providers, payment service providers, etc.
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
Credit reporting agencies;
Our insurers and brokers;
Our bank.
We only allow our service providers to handle your personal information if we believe they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. Nonetheless, to the fullest extent permitted by applicable law, the use of your personal information by our service providers is governed by the privacy policies of each individual provider and is not subject to BEOA’s control.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may also need to share some personal information with other parties. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
5. Personal Information We Disclosed for a Business Purpose.
In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
Personal Information Categories. Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
Professional or employment-related information (e.g current or past job history, professional evaluations, etc.)
Related Inferences. Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
6. Personal Information We Sold.
In the preceding 12 months, we have not sold your personal information to third parties. BEOA does not sell or rent your personal information collected during your use of our website without your permission.
7. Promotional Communications.
We may use your personal information to send you updates (by email, text message, telephone or post) about BEOA, BEOA’s mission, membership in BEOA, and our services, including exclusive offers, promotions, contests or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
You may to opt out of receiving promotional communications at any time by:
Contacting us with your request by email or post (see below “How to Contact Us”); or
Using the “unsubscribe” link in emails or “STOP” number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or BEOA’s operations.
8. What are Cookies and similar technologies and how do we use them?
Our website uses “cookies” to help BEOA understand which parts of our website are the most popular, where website visitors are going, and how much time they spend there. BEOA also uses cookies to customize your experience. If, however, you prefer not to enable cookies, you can disable cookies on your web browser. Please note that certain features of our website will not be available once cookies are disabled.
BEOA may gather certain other information automatically and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. BEOA may use this information, which does not identify BEOA’s individual users, to analyze trends, to administer the site, to track BEOA’s users’ movements around the site and to gather demographic information about BEOA’s user base as a whole. BEOA may also use pixel tags—tiny graphic images—and other technologies to tell BEOA what parts of our website users have visited or to measure the effectiveness of searches users perform on our website.
BEOA currently uses Google Analytics to provide website analysis. Information regarding how Google Analytics tracks your data can be found here. Information regarding how to prevent Google Analytics’ use of such data can be found here.
BEOA currently uses Later to provide social media marketing services. Information regarding how Later tracks your data can be found here.
BEOA currently uses Sprout Social to provide social media management services. Information regarding how Sprout Social tracks your data can be found here.
BEOA currently uses Typeform to provide to conduct research and surveys. Information regarding how Typeform tracks your data can be found here.
BEOA currently uses SquareSpace to provide website hosting services and analytics. Information regarding how SquareSpace tracks your data can be found here.
BEOA currently uses MailChimp to provide email delivery and marketing services. Information regarding how MailChimp tracks your data can be found here. Information regarding how to prevent MailChimp’s use of such data can be found here
BEOA currently uses Square to provide credit card processing services. Information regarding how Square tracks your data can be found here.
BEOA currently uses PayPal to provide credit card processing services. Information regarding how PayPal tracks your data can be found here. Information regarding how to prevent PayPal’s use of such data can be found here.
BEOA currently uses BDE to provide electronic data storage and processing. Information regarding how BDE tracks your data can be found here.
BEOA does not respond to do not track signals.
In some email messages, BEOA may use a “click-through URL” linked to content on the Internet. When users click one of these URLs, they pass through BEOA’s web server before arriving at the web page. BEOA tracks this click-through data to help BEOA determine interest in particular topics and measure the effectiveness of BEOA’s communications. If you prefer not to be tracked simply avoid clicking text or graphic links in the email.
9. BEOA is Not Responsible for the Privacy Policies or Practices of Third Parties
This Policy does not apply to information collected by any third party. Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information BEOA collects from You. BEOA is not responsible for the policies or practices of third parties, including without limitation, the policies or practices of Later, Sprout Social, Typeform, Squarespace, MailChimp, Square, PayPal, LinkedIn, Instagram, or Facebook who may also use cookies or other tracking technologies. BEOA does not control these third parties’ tracking technologies or how they may be used. If you have any questions about targeted content, or any questions about their use of the information that they collect, you should contact the responsible provider directly. For a current list of our third-party service providers, contact us with your request by email or post (see below “How to Contact Us”).
10. Where Your Personal Information is Held.
Information may be held at our offices and those of our service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
Some of these third parties are based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.
11. How Long Your Personal Information Will Be Kept.
We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
12. Transferring Your Personal Information Out of the EEA.
To deliver services to you, it is necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
With our offices outside the EEA;
With your and our service providers located outside the EEA;
If you are based outside the EEA; or
Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, require the transfer complies with data protection law and all personal information will be secure. If you would like further information, please contact us (see “How To Contact Us” below).
13. Your Rights Under the GDPR.
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.
14. Your Rights Under the CCPA.
You may have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws to exercise free of charge, including:
Disclosure of Personal Information We Collect About You:
You have the right to know:
The categories of personal information we have collected about you;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting or selling personal information;
The categories of third parties with whom we share personal information if any; and
The specific pieces of personal information we have collected about you.
Please note that we are not required to:
Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
Provide personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose:
In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
The categories of personal information that we disclosed about you for business purposes.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt out of the sale or disclosure of your personal information. If you exercise your right to opt out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information.
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Delete your personal information from our records; and
Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
Complete the transaction for which the personal information was collected, provide a service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
Debug to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act;
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
Comply with an existing legal obligation; or
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.
15. Keeping Your Personal Information Secure.
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
16. How to Exercise Your Rights.
If you would like to exercise any of your rights as described in this Privacy Policy, please contact us by email or by post (see “How to contact us” below). You will need to provide us with:
Enough information to identify you;
Proof of your identity and address; and
A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
17. How to File a GDPR Complaint.
We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. For more information, please contact us by email or by post (see below “How to Contact us”)
18. Changes to This Privacy Notice.
This privacy notice was published on 7/26/22 and last updated on 7.27/22. We may change this privacy policy from time to time. When we do, we will add notices to our website. By continuing to access or use our services after those changes become effective, you agree to be bound by the revised privacy policy.
19. How to Contact Us.
If you have questions or concerns about BEOA’s Privacy Policy or data processing, please contact BEOA at the following address:
Be Original Americas
c/o BDE
665 Broadway, Suite 704
New York, NY 10012
info@beoriginalamericas.com