Behavior Science Technology Privacy Policy

 

Behavior Science Technology Inc. (“BST”, “We”, “Our”, or “Us”), headquartered at 16 Wichard Blvd., Commack, NY 11725, is committed to protecting your privacy. This Privacy Policy (this “Privacy Policy”) describes how We collect, use and share Personal Information about you, and how you can exercise your privacy rights. “Personal Information” means any information relating to an identified or identifiable individual (e.g., name, address, email address, or phone number).

 

Applicability of this Privacy Policy

This Privacy Policy describes the policies and procedures of BST with respect to the collection, use, access, correction, and disclosure of your Personal Information on behaviorsciencetech.com (the “Site”), Our clinical performance management platform accessible at bstperform.com (the “Platform”), and any services you may receive from BST (the “Services”). This Privacy Policy additionally covers any of your Personal Information which is provided to Us, and which is used in connection with the marketing of the Platform, Services, features or content by BST, its subcontractors or Subprocessors (as defined below), Service Providers (as defined below), and third parties. This Privacy Policy also describes the choices available to you regarding the use of, your access to, and your rights in relation to your Personal Information, generally, and pursuant to applicable regulations for California residents.

This Privacy Policy does not apply to any third-party applications or software that can be accessed from the Site, Platform, or the Services, such as social media websites or partner websites (“Third-Party Services”).

Where applicable, a separate agreement may govern the delivery, access, and use of the Platform and/or Services between BST and a customer of BST (the “Customer”, and such agreement, the “Customer Agreement”). The Customer that entered into the Customer Agreement with BST may authorize Us to collect, process, and store your Personal Information and associated Customer data. If you have any questions about the information BST has been authorized by a Customer to process on your behalf, you may contact the Customer that has authorized such collection, processing and/or storage by BST.

 

Information We Collect and Receive About You and How We Use It

We generally collect and process the following types of Personal Information:

Information You or Your Employer, or a Customer, Provides Us:

  • Account-Related Personal Information. When using the Site, Platform, or Services, you, your employer that is a Customer, or a Customer for whom you may be working as a contractor, may choose to provide Us with certain Personal Information, such as your name, profile photograph, employment details (including certain performance-related information), email address, phone number, and other contact information. While provision of much of your Personal Information is mandatory for use of the Platform and Services, certain Personal Information collected for account-related purposes is elective and you or your employer may choose to provide or not at your discretion. Any account-related Personal Information you or the Customer with which you are associated provide is used to: (i) provide login information to the Platform as well as to carry out Platform processing functions and the Services BST has been contracted to provide by such Customer; (ii) communicate with you by responding to your requests, comments and questions; (iii) improve the Site; and (iv) perform various account functions provided by BST.

  • Data Collected through Customer Use of the Platform and Services. When providing access to the Platform or providing certain Services, BST collects information under the direction of its Customers. The Customer Agreement may govern the delivery, access, and use of the Platform and Services, including the processing of Personal Information and data submitted through Customer users and accounts. The Customer controls their Platform instance and any associated Customer data as described in the Customer Agreement. If you have any questions about specific Platform settings, the processing of Personal Information in the Platform, or its privacy practices, please contact the associated Customer. Customer data will be used by BST in accordance with the Customer’s instructions, the applicable terms in the Customer Agreement, the Customer’s election of various Platform and Services functionalities, this Privacy Policy, and as required by applicable law. In such cases, BST acts as the data processor of Customer data at the direction of the Customer, who acts as the data controller.

  • Contact Information. When you express an interest in obtaining additional information about the Site, Platform, or Services, BST may ask you to provide your personal contact information, such as your name, email address, and phone number. We use this information to communicate with you by responding to your requests, comments, and questions. The legal basis for processing this information is the legitimate interest in communicating with you and answering your questions.

  • Device Information. We use analytics software to allow Us to better understand how the Platform functionality performs on your phone or computer. Information such as how often you use the Platform, the events that occur within the Platform, aggregated usage, performance data, and how and from where the Platform was accessed may be recorded by such software. The information We store within the analytics software is not linked to any Personal Information you submit, or that may be submitted, within the Platform. We automatically collect your device information such as operating system version, type, hardware usage statistics, etc. when you access the Platform

  • Location Information. Except as described in this Privacy Policy, We do not track, access or ask you for, any location-based information from your device at any time while using the Platform.

  • Log Data.  As is common, We collect certain information automatically when you visit the Site or access the Platform. Included within this information is Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the content viewed on Our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

  • Tracking Technologies. We may use cookies or similar technologies to analyze trends, administer the Site and the Platform, track users’ movements around the Site and the Platform, and to gather demographic information about Our user base as a whole. Within your web browser, You can control the use of cookies, but if you choose to disable cookies, it may limit your use of certain features or functions on the Site or Platform, or Our ability to perform certain Services.

 

Other Information:

  • Social Media Features. The Site and Platform may include social media features, such as the “Like” button and certain widgets, the “Share This” button or interactive mini-programs that run on the Site or Platform. These features may collect your IP address, which page you are visiting on the Site or Platform, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site or the Platform. Your interactions with these features are governed by the privacy policy of the company providing such service.

  • Single Sign-On. If applicable, You can log in to the Platform using sign-in services such as an Open ID provider. These services will authenticate your identity and provide you the option to share certain Personal Information with Us such as your name and email address to pre-populate Our sign-up form.

 

How, and With Whom, Your Information Is Shared:

  • Third-Party Services.  At times, you may be able to access Third-Party Services through the Site or via the Platform. BST is not responsible for the privacy policies and/or practices of these Third-Party Services, and you or the Customer through which you are accessing the Site and/or Platform are responsible for reading and understanding those Third-Party Services’ privacy policies. You or such Customer’s purchase of such Third-Party Services shall serve as consent to BST’s use and collection of your information pursuant to the Third-Party’s applicable privacy policy.

  • Information Shared with Our Subprocessors.  Certain tasks are performed for Us by individuals and entities that We employ and with whom we contract (collectively, “Subprocessors”).  These Subprocessors may in some instances collect your data and Personal Information on Our behalf, subject in all cases to their contractual obligations with Us and in accordance with the privacy and security standards that we have established. Subprocessors include, but are not limited to, email service providers, data storage providers, and other services that support the Site, Platform and certain Services provided to you or the Customer through which your Personal Information is being used or processed by BST. In order to provide the Site, the Platform, or the Services to you, We may need to share Personal Information with Subprocessors. Except as We otherwise inform you, Our Subprocessors do not have any right to use Personal Information or other information We share with them beyond what is necessary to assist Us in the provision of Site, Platform and/or Services on your behalf, or on behalf of the Customer through which your Personal Information is being used or processed by BST. Written agreements between BST and each Subprocessor govern transfers of your Personal Information.

  • Information Shared with Our Service Providers.  We may share your information with entities with which BST has contracted to provide certain services to Us (“Service Providers”) on your behalf, or on behalf of the Customer through which your Personal Information is being used or processed by BST. These Service Providers are authorized to use your Personal Information only as necessary to provide the contracted services to BST, and in furtherance of such services, and may not collect, sell, retain or use your Personal Information except in such context.

  • Information Disclosed Pursuant to Business Transfers.  If We may buy or sell business assets, user information is usually a part of the transferred business assets. Additionally, if We, or substantially all of Our assets, are acquired, or if We cease to conduct Our business or enter bankruptcy, a third party may acquire or have transferred to them user information. You acknowledge that it is possible that such transfers occur, and that your Personal Information may be continued to be used by any acquirer of BST, subject to the terms and conditions of this Privacy Policy. You will be notified via email and/or a notice on the Site if the legal owner or uses of your Personal Information changes, as well as any choices you may have regarding your Personal Information.

  • Information Disclosed for Legal Purposes.  In certain situations, We may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also reserve the right to access, read, preserve, and disclose any information as We reasonably believe is necessary to: (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy, including without limitation, investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to user support requests; or (v) protect Our rights, property, or safety. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

 

We require all Third Parties, Subprocessors, Service Providers and subcontractors to respect the security of your Personal Information and to treat it in accordance with applicable laws. We do not allow Subprocessors and subcontractors to use your Personal Information for their own purposes and only permit them to process your Personal Information for a specified purposes in accordance with Our instructions or the provision of services on BST’s behalf, and strictly as detailed herein.

Except as set forth above, you will be notified when your Personal Information is shared with third parties, and will be able to prevent the sharing of this information. Unless We otherwise have your consent, We will only share your Personal Information in the ways that are described in this Privacy Policy.

 

Data Retention

Subject to applicable law or regulation, in certain cases, We will retain your Personal Information and the Personal Information We process on your behalf, or on behalf of the Customer through which we have obtained your Personal Information for as long as your or such Customer’s account is active or as needed to provide you or such Customer’s access to the Platform or to perform certain Services in accordance with BST data retention policies, and as necessary to comply with Our legal obligations, resolve disputes, and enforce Our agreements. In certain cases, and as detailed further herein, you may request removal of your Personal Information by contacting privacy@behaviorsciencetech.com. In order to determine whether or not we are required to retain your Personal Information, your right to removal of your Personal Information is subject to applicable law or regulation, and may be further subject to BST’s obligation on behalf of the Customer that authorized the collection of your Personal Information to provide access to the Platform or to provide certain Services.

 

Data Security

The security of your Personal Information and Our Customers’ information is important to Us. We put in place appropriate technical and organizational measures to ensure your Personal Information is kept secure and protected from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. When you enter sensitive information (such as login credentials), We encrypt the transmission of that information using Transport Layer Security (TLS). We follow generally accepted standards to protect the Personal Information submitted to Us, both during transmission and once We receive it. When We share your Personal Information with Subprocessors, Service Providers, subcontractors or other Third Parties, We base our selection on said partners having adequate safeguards in place as detailed herein and that meet Our data protection standards. We ensure their compliance with such standards and incorporate contractual provisions ensuring compliance with: (i) such standards; and (ii) applicable data privacy laws and regulations.

You can contact Us at privacy@behaviorsciencetech.com if you have any questions about security on the Site, the Platform, or Services.

 

Cross Border Transfers of Personal Information

The Site, Platform and Services are hosted in and managed from the United States. We may transfer the Personal Information We collect about you to another country, which may not be deemed to have the same data protection laws as the country in which you initially provided the information.

If you are located outside the United States, you understand (and, as permitted under applicable law, consent to) having any Personal Information processed in the United States. When we transfer your Personal Information, we will protect that information as described in this Privacy Notice.

 

California Data Privacy

California residents have certain privacy rights as specified under California law, including the California Consumer Privacy Act of 2018 (“CCPA”). If you are a resident of California, you have the right to know what Personal Information has been collected about you, and to access that information. You have the right to request deletion of your Personal Information, though exceptions under the CCPA may allow Us to retain and use certain personal information notwithstanding your deletion request.

We collect various categories of Personal Information when you or the Customer through which we have obtained your Personal Information use the Platform or Services, including location information, log data, and tracking information. You can find a more detailed description of the information We collect and how We use it above in this Privacy Policy.

In addition to Our collection of your Personal Information, We may engage certain Subprocessors, Service Providers, Third Parties and subcontractors to perform a function or provide services on Our behalf, including hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer and account relationship management, database storage and management, and direct marketing campaigns. We may share your Personal Information with these Third Parties, Subprocessors, Service Providers and subcontractors, but only to the extent necessary to perform these functions and provide access to the Site or Platform, and to provide the Services as detailed herein.  We require these organizations to maintain the privacy and security of the Personal Information they process on Our behalf, as detailed further as set forth above in this Privacy Policy.

We do not sell your Personal Information when you use the Platform or the Service and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. We do not offer financial incentives associated with the collection, use, or disclosure of your Personal Information.

We will not discriminate against you for exercising any of your CCPA rights. To this end, unless permitted by the CCPA, We will not:

  • Deny you access to the Platform or Services;

  • Charge you a different price or rate for the Platform or Services, including the granting of discounts or other incentives;

  • Provide a different or downgraded Platform or Service;

  • Suggest that you may receive a different price or rate for the Platform or Services or a different or downgraded Platform or Service.

To exercise your rights under the CCPA please submit a verifiable consumer request to BST by either calling BST at 1-631-805-3657 by or emailing us at privacy@behaviorsciencetech.com. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access to your data twice within a twelve (12) month period. Your verifiable consumer request must:

  • Be made by a natural person;

  • Provide sufficient information to allow BST to reasonably verify your identity and that you are the person about whom We collected Personal Information, or you are an authorized representative;

  • Describe your request with sufficient detail that allows BST to properly understand, evaluate, and respond to your request.

In certain cases, We collect and process your Personal Information as a contractual obligation to a Customer. We may be required to provide notice to that Customer of your request, and to follow that Customer’s instructions as they relate to carrying out your request, in order to respond to a verified request.  We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. You don’t have to create an account to make a verifiable consumer request, but if you have one, we may ask you to verify your request by logging into your account. We will only use Personal Information provided by a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

Changes to this Privacy Policy

BST may amend this Privacy Policy from time to time to reflect changes to applicable laws and regulations or other requirements applicable to Us, changes in technology, or changes to Our information practices. Our use of Personal Information We collect is subject to the Privacy Policy in effect at the time such information is used. If We make material changes in the way We collect or use information, We will notify you by posting an announcement on Our Site or in the Platform, or by sending you an email prior to the changes becoming effective.

 

Contacting BST If You Have Questions or Concerns

If you have any questions or concerns regarding this Privacy Policy, please send Us a detailed message to privacy@behaviorsciencetech.com or at our mailing address at 16 Wichard Blvd., Commack, NY 11725. We will make every effort to resolve your concerns.

Effective Date: August 21, 2021.