Privacy Policy

Last updated November 7th, 2024

This privacy notice for BastionX.io INC. (doing business as BastionX) (“we,” “us,” or “our“) describes how and why we might collect, store, use, and share (“process“) your information when you use our services, such as when you:

• Visit our website at https://www.bastionx.io or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you disagree with our policies and practices, please do not use our Services. If you still have questions or concerns, please get in touch with us at info@bastionx.io. 

 

Summary of Key Points

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our services, we may process personal information depending on how you interact with us and the services, the choices you make, and the products and features you use. Learn more about the personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and outside sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide, improve, and administer our services, communicate with you, ensure security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent. We process your data only when we have a valid legal reason. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your info safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request or contacting us. We will consider and act upon any request per applicable data protection laws.

 

Table of Contents

1. What information do we collect?

2. How do we process your information?

3. What legal bases do we rely on to process your personal information?

4. When and with whom do we share your personal information?

5. Do we use Cookies and other technologies?

6. How do we handle your social logins?

7. How long do we keep your information

8. How do we keep your information safe?

9. Do we collect information from minors?

10. What are your privacy rights?

11. Controls for Do-Not-Track features

12. Do United States residents have specific privacy rights?

13. Do other regions have specific privacy rights?

14. Do we make updates to this notice?

15. How can you contact us about this notice?

16. How can you review, update, or delete the data we collect from you?

17. SMS Mobile Message Marketing Program

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide us when you register on the Services, express an interest in obtaining information about us or our products and Services when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect depends on the context of your interactions with us and the Services, your choices, and the products and features you use. The personal information we collect may include the following:

• Name
• Phone numbers
• Email addresses
• Mailing addresses
• Job titles
• Username
• Password
• Contact preferences
• Contact or authentication data

Sensitive Information. We do not process sensitive information.

Social Media Login Data. We may allow you to register with us using your existing social media account details, like your Facebook, X, or other social media accounts. If you choose to register this way, we will collect certain profile information about you from the social media provider, as described in the section “How do we handle your social logins?” below.

All personal information you provide must be true, complete, and accurate, and you must notify us of any changes to such individual.

Information automatically collected

In Short: Some information – such as your Internet Protocol (P) address and browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information). Still, it may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical details. This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages, and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the services. Depending on the device used, this data may include your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data, such as information about your device’s location, which can be precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by turning off the location setting on your device. However, if you opt out, you may not be able to use certain aspects of the services.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Information we collect from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

To enhance our ability to provide relevant marketing, offers, and services and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles for targeted advertising and event promotion.

Suppose you interact with us on a social media platform using your social media account (e.g., Facebook or X). In that case, we receive your personal information from platforms, such as your name, email address, and gender. Any personal information we collect from your social media account depends on your social media account’s privacy settings. Please note that this privacy notice does not govern their use of your information.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you for security and fraud prevention, and comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges through the Services.
• To enable user-to-user communications. We may process your information if you use any of our offerings to communicate with another user.
• To request feedback. We may process your information when necessary to request feedback and contact you about using our Services.
• To send you marketing and promotional communications. We may process the personal information you send us for our marketing purposes if this is per your marketing preferences. You can opt out of our marketing emails at any time. See “What are your privacy rights?” below for more information.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
• To protect our services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to understand better how they are used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to understand better how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with regulations, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

This section applies to you if you are in the EU or UK.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have permitted us (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request before entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described:
  • Send users information about special offers and discounts on our products and services
  • Develop and display personalized and relevant advertising content for our users
  • Analyze how our Services are used so we can improve them to engage and retain users
  • Support our marketing activities
  • Diagnose problems and prevent fraudulent activities
  • Understand how our users use our products and services so we can improve user experience
• Legal Obligations. We may process your information where we believe it is necessary to comply with our legal obligations, such as cooperating with a law enforcement body or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a particular purpose or in situations where your authorization can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations, fraud detection, and prevention
• For business transactions, provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be the victim of financial abuse.
• Suppose it is reasonable to expect collection and use with consent. In that case, it will compromise the availability or the accuracy of the information, and the collection is reasonable for purposes related to investigating a breach of an agreement or an infringement of the laws of Canada or a province.
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

4. When and with whom do we share your personal information?

We will not sell, rent, or lease mailing lists or other user data to others, and we will not make your personal information available to any unaffiliated parties except as follows:

• To agents, website vendors, and contractors who may use it on our behalf or in connection with their relationship with us
• If we cannot assist with your matter but know an unaffiliated attorney or firm that may be able to help you, we may refer you and share the information you provided us with that party.
• As required by law, in a matter of public safety or policy, as needed in connection with the transfer of our business assets (for example, if another firm acquires us or if we are liquidated during bankruptcy proceedings), or if we believe in good faith that sharing the data is necessary to protect our rights or property.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. We may use the Google Analytics Advertising Features: Google Analytics Demographics and Interests Reporting, Google Display Network Impressions Reporting, and Remarketing with Google Analytics. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other options for opting out include https://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on Google’s privacy practices, please visit the Google Privacy & Terms page.

6. How do we handle your social login?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our services allow you to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned but will often include your name, email address, friends list, profile picture, and other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes described in this privacy notice or otherwise made clear to you on the relevant services. Please note that we do not control and are not responsible for other uses of your personal information by your third-party social media provider. We recommend reviewing their privacy notice to understand how they collect, use, and share your personal information and how you can set your privacy preferences on their sites and apps.

7. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a more extended retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your data has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How do we keep your information safe?

In Short: We aim to protect your personal information through organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to delete such data from our records promptly. If you become aware of any data we may have collected from children under the age of 18, please get in touch with us at info@bastionx.io

10. What are your privacy rights?

In Short: Depending on your state of residence in the US or some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

You have certain rights under applicable data protection laws in some regions (like the EEA, UK, Switzerland, and Canada).

These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv), if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to processing your personal information. You can make such a request by contacting us using the contact details provided in the section “How can I contact you about this notice?” below.

We will consider and act upon any request per applicable data protection laws.

Suppose you are in the EEA or UK and believe we are unlawfully processing your personal information. In that case, you also have the right to complain to your Member State or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and implied consent, depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent anytime by contacting us using the contact details provided in the section “How can I contact you about this notice?” below or by updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided in the section “How can you contact us about this notice?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages necessary for your account’s administration and use, respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
  Contact us using the contact information provided.
• Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.

However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at info@bastionx.io.

11. Controls for Do-Not-Track features

Most web browsers, mobile operating systems, and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference and not to have data about your online browsing activities monitored and collected.

No uniform technology standard for recognizing and implementing DNT signals has been finalized at this stage. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

California law requires us to let you know how we respond to web browser DNT signals. Our web services do not alter, change, or respond upon receiving Do Not Track (DNT) requests or signals in browsers. As described above, we track user activity using web server logs, cookies, and similar technologies. Information collected in web server logs helps us analyze website usage and improve the user’s experience. Cookies allow us to offer you a customized experience and present relevant advertising.

12. Do United States residents have specific privacy rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months: