We are Bettermode Inc ("Bettermode"), a Canadian registered company. We provide customer community platform allowing brands to connect to their communities “Customer communities”, as more fully described on our websites (our "Services"). We operate the websites available at: bettermode.com, together with the individual sub-sites created by our subscribers (the "Websites").
This policy does not set out the information collected in the Customer communities – this information is set out in the privacy policies made available in those Customer communities. Any access requests or similar from members of Customer communities will be directed to the subscriber who created that community.
Our Privacy Officer may be contacted using the contact details set out at the bottom of this policy.
It is always a User’s choice whether or not to provide Personal Information. However, if a User chooses not to provide requested Personal Information, that User will not be able to use certain features of the Services. We set out in detail below the information that we collect about Users and Users’ use of our Services. Bettermode does not intentionally collect things like protected health information, financial information, date of birth, social security or other government-issued identification number, and other sensitive personal information from Users.
- The Information We Collect About Users
Personal data, or personal information, means any information relating to an identifiable person who can be directly or indirectly identified. It does not include data which cannot be related to an identifiable person (anonymous data).
We may collect, use, store and transfer different kinds of personal information about Users which we have grouped together follows:
- Identity Data includes first name, last name or similar identifier.
- Contact Data includes email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, browser type and version, operating system and platform
- Usage Data includes information about how Users use our Services, such as browsing actions within the portal, the buttons, controls, Users click on, pages of our portal that Users visit, the time spent on those pages, User’s search queries, the dates and times of User’s visits, and workplace usage.
We also collect, use and share Non-personalized data called “Service Data” such as statistical or demographic data for any purpose. Service Data may be derived from User’s personal information but is not considered personal information in law as this information does not directly or indirectly reveal User’s identity. For example, we may aggregate User’s Usage Data to calculate the percentage of users accessing a specific Website feature.
We do not collect any Special Categories of Personal Data about Users (this includes details about User’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about User’s health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- How Is User’s Personal Information Collected
We use different methods to collect data from and about Users including through:
- Direct interactions. Users may give us User’s Identity, Contact and Profile Data by registering for the Service and completing fields within the Service
- Automated technologies or interactions. As Users interact with our Service, we may automatically collect Technical and Usage Data about User’s equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal information about Users from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google Analytics;
- search information providers such as Google.
- Purposes for Which We Will Use User’s Personal Information
We have set out below, in a table format, a description of all the ways we plan to use Users’ personal information.
- To contractors, service providers, and other third parties we use to support our business solely for the purpose of them providing services to us.
- To fulfill the purpose for which Users provide it.
- For any other purpose expressly disclosed by us when Users provide the information.
- To our subsidiaries and affiliates where they are providing.
We may also disclose User’s Personal Information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Bettermode, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Upon request, Bettermode will provide Users with information about whether we hold any of User’s Personal Information. Bettermode enables customers and website visitors with the ability to access and correct Personal Information we have collected. If Users have any concerns or suspect unauthorized activities associated with User’s account, please contact us at [email protected] We will respond to User’s request within a reasonable timeframe, and in any event within 30 days of receipt of request.
Bettermode acknowledges that Users have the right to access, update, revoke permission to process, or request the deletion of User’s Personal Information. Any such query can be directed to Bettermode’s Data Protection Officer at [email protected] If requested to remove data under either scenario, we will respond within a reasonable timeframe.
8. Security and Enforcement
The security of User’s Personal Information is important to us. We use security safeguards appropriate to the sensitivity of the information to ensure that User’s Personal Information is stored and maintained in a secure environment. Bettermode exercises managerial and technical safeguards designed to protect against the loss or unauthorized use or disclosure of Personal Information belonging to our customers and website visitors. These safeguards include encryption, malware protection, logical and physical access controls, and detection of social engineering attacks.
9. Managing the Online Collection of Additional Data
As Users navigate through and interact with our Website and Services, we may use automatic data collection technologies to collect certain information about User’s equipment, browsing actions and patterns, location, and workplace usage patterns, including:
- Details of User’s visits to our Website and other communication data and the resources that Users access and use on the Site or App.
- Information about User’s computer and Internet connection, including User’s IP address, operating system, and browser type.
- We also may use these technologies to collect information about User’s online activities over time and across third-party websites or other online services (behavioral tracking).
- We may collect information about User’s mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
- Our App collects real-time information about the location of User’s device.
We and our third-party service providers may collect information about Use in a variety of ways. We and/or our third-party partners may employ various tracking technologies, such as cookies, web beacons and analytics software, that help us better manage content on our Service by informing us what content is effective.
When Use visit our website or otherwise interact with the Service, we (or third-party data or ad networks we work with) may send one or more “cookies” to User’s computer or other devices. Cookies are alphanumeric identifiers stored on User’s computer through User’s web browser and are used by most websites to help personalize User’s web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third-party websites. Some features on this site will not function if Use do not allow cookies. We may link the information we store in cookies to any Personal Information Use submit while on our site.
Functional cookies, persistent and session type, store information to enable core site functionality.
Analytics cookies allow us to count page visits and traffic sources, so we can measure and improve the performance of our site and our marketing campaigns.
9.2 Web Beacons
We (or third-party data or ad networks we work with) may use Web Beacons alone or in conjunction with cookies to compile information about our Service, or other information we or they have collected. Web Beacons are tiny graphic objects that are embedded in a web page or email and are usually invisible to the user but allow checking that a user has viewed the page or email. Web Beacons may be used within the Service to track email open rates, web page visits or form submissions. In some cases, we tie the information gathered by Web Beacons to our Users’ Personal Information. For example, we use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
9.3 Flash and HTML5 Storage
We use Local Shared Objects, such as Flash cookies, AND/OR Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website upon User’s web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
9.4 Do Not Track Signals
At this time, we do not respond to browser ‘do not track’ signals.
10. Transfers of Data
Bettermode’s headquarters in Canada is our primary location for business operations. Servers hosting the Bettermode platform are located in the US unless agreed as part of a separate agreement.
For example, regarding normal business operations, Bettermode may engage a third-party to support our billing, support services, information technology, or mailings on our behalf.
We may also disclose User’s Personal Information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect User’s safety, or the safety of others, investigate fraud, or respond to a government request.
11. Outside Parties and Sites
12. Additional Privacy Protections for Minors
We join the industry in recognizing that children, including young teens, may not be able to make informed choices about Personal Information requested online. Bettermode does not knowingly solicit or collect Personal Information targeted at those under the age of thirteen. Bettermode’s Terms of Service (TOS) does not permit the use of the Website and/or Services by users under the age of thirteen.
13. Data Retention
Bettermode will keep User’s Personal Information for as long as it remains necessary for the identified purposes in Section 5 or as required by law, which may extend beyond the termination of our relationship with User. Users acknowledge and agree that if User request that User’s name be removed from our databases, it may not be possible to completely delete all User’s Personal Information due to legal constraints.
Message & file retention
For any community, the default post and file retention setting is to keep everything for as long as the community exists. On the enterprise plan, the customer can customize their retention policies. You can choose to set a custom time frame to keep posts and files, and you can also choose to retain all versions of an edited or deleted message.
Edited and deleted messages
When users or moderators edit or delete a message, only the most recent version will remain. On the Enterprise plan, the customer can choose to keep a log of all edited posts.
14. RESIDENTS OF THE EUROPEAN UNION (EU)
Bettermode generally processes Personal Information in order to fulfill contracts we have with our customers and end users and to pursue our legitimate business interests listed above. Otherwise, Bettermode will obtain consent from an individual with respect to the processing of Personal Information if required by law to do so.
Further, individuals located in the EU have certain rights under European law (including under the General Data Protection Regulation) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of User’s personal data. Individual end users, customers or prospective customers located in the EU who wish to exercise these rights, should contact Bettermode using the contact information below in Section 16. If we are processing User’s information on behalf of a third party then User should contact that party directly because Bettermode serves as a data processor on behalf of third party in that instance and can only forward User’s request to the buyer to allow them to respond. Individuals also have the right to make complaints to regulatory authorities in respect of our privacy practices.
We value your data subject rights under GDPR and therefore “GDPR-Rep.eu” has been designated as Bettermode’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. GDPR-Rep.eu may be contacted only on matters related to the processing of Personal Data. If you want to make use of your data subject rights, visit https://gdpr-rep.eu/q/14418454. Please add ‘GDPR-REP ID: 14418454’ to all correspondence, which may be addressed to:
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o Bettermode Inc.
Schellinggasse 3/10, 1010 Vienna, Austria
16. Contact information.
Data Protection Officer
1607 - 22 Wellesley St. East, Toronto, ON, M4Y 1G3