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Privacy & Cookies Policy

BEE Content Design, Inc., with registered office at 450 Townsend St., San Francisco, CA 94107, USA (“BEE”), makes constant efforts to safeguard the privacy of users of its software (the Software) and website https://beefree.io/ (“Website” and, together with the Software, the “Digital Properties”). We have prepared this document (the “Privacy Notice”) to explain how your Personal Data, as defined below, will be processed within our Digital Properties. The Privacy Notice provides you with the information you need in order to express explicit and informed consent to the processing we conduct, if you agree with it.

In general, any information or Personal Data you provide to BEE through our Digital Properties, or that is collected in any other way through the Platform as you use the services BEE provides (the “Services”), as better defined in subsequent Paragraph 3, will be processed in accordance with the internationally acknowledged principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity and confidentiality.

This Privacy Policy must be read in conjunction with (i) the Terms of Service of one of our Services as time per time available on our Website and (ii) this page: https://beefree.io/gdpr/.

CONTENTS

  1. Data Controller and Data Protection Officer
  2. The Personal Data we process
    1. Name, contact details and other Personal Data
    2. Special categories of Personal Data
    3. Data voluntarily provided by the Data Subject
    4. Data automatically collected when sending e-mails or communications.
    5. Browsing data
    6. Cookies
  3. Purpose of processing
  4. Lawful basis and mandatory or optional nature of processing
  5. Recipients of Personal Data
  6. Transfers of Personal Data
  7. Storage of Personal Data
  8. Rights of the Data Subject
  9. Amendments

1. Data Controller and Data Protection Officer

BEE, as identified in the opening to this Privacy Notice, is the Data Controller for all Personal Data processed through the Platform.

You can contact BEE’s Data Protection Officer (“DPO”) at the following address: dpo@beefree.io .

2. The Personal Data we process

As you use the Digital Properties, BEE will process your Personal Data which, depending on your decisions on how you use the Services, may consist of an identifier such as your name, an identification number, an on-line identifier (hereinafter, simply “Personal Data).

We collect the data you provide voluntarily (for example, when you create an account, request assistance or if you decide to take part in the market research and surveys we periodically conduct through the Software), as well as data from analysis of your activities on the Digital Properties.

We process the following types of Personal Data:

  1. Name, contact details, and other Personal Data

For you to access and use the Software, you must create an account. To do this we need you to provide us with your e-mail address, a password, your name, last name, and your company name (if any). BEE may also collect any additional information you decide to provide through market research or surveys.

The same information may be collected in various sections of the Website, including, particularly, areas where you request the Services or when you ask for information relating BEE’s Services.

This personal data is processed in accordance with sections 3 (a) to (f) of this Policy.

  1. Special categories of Personal Data

Certain areas of the Platform (e.g. the Contact form) may include open text fields, where you can provide to BEE information which may contain Personal Data.

As these fields are completely open, you may use them to disclose (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you insert or upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.

BEE asks that you do not disclose these kinds of Personal Data, unless you consider this to be strictly necessary. Please mind know that these sensitive categories of Personal Data can only be processed with your explicit consent, in compliance with the current legislation. BEE underlines the importance to express your explicit consent to process this sort of Personal Data, where you to decide to share them.

This personal data is processed in accordance with sections 3 (a) of this Policy.

  1. Data voluntarily provided by the Data Subject

As mentioned in the previous section, certain areas of our Digital Properties allow you to post various types of content, available to BEE which may include Personal Data related to other persons.

In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify BEE against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Software and/or the Website.

In any case, if you provide or otherwise process Personal Data of third parties when using our Digital Properties, you guarantee from now on – assuming all related liability – that your particular processing hypothesis is based on the consent of the third party concerned or on another appropriate legal basis legitimising the processing of the Personal Data of third parties.

This personal data is processed in accordance with sections 3 (a), (e) and (f) of this Policy.

  1. Data automatically collected when sending e-mails or communications.

When we send e-mails or other forms of communications we use, with the explicit and freely provided consent of the user, tracking systems, such as pixel or web beacons, in order to detect the opening of a message, the clicks made on hyperlinks the IP address or the type of browser used to read the message and other similar details.

This personal data is processed in accordance with sections 3 (a) to (f) of this Policy.

  1. Browsing data

The computer systems and software procedures used to operate the Software and the Website acquire certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information which could, by its very nature, through processing and association with data held by third parties, permit the identification of users. This category of data includes IP addresses or domain names of the computers used by users connecting to the Software, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment. This data is used only to generate anonymous statistical information on the use of the Software, to check its correct operation and identify anomalies and/or abuses.

In addition, the Website’ operation, as is standard with any Website on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While BEE does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.

This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and other parameters related to the operating system and user’s IT environment.

These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website. Save for this last purpose, these data are kept as long as they are needed for the specific purpose described above.

This personal data is processed in accordance with sections 3 (d), (e) and (f) of this Policy.

  1. Cookies

Definitions, characteristics, and application of the legislation

Cookies are small text files that sites you visit send and record on your computer or mobile device, which are re-transmitted to the same sites on your next visit. Through the use of cookies, sites remember your actions and preferences (such as, for example, login data, the chosen language, font size, other display settings, etc.) to avoid having to enter them again when you return to the site or browse its pages. Cookies are used mainly for authentication purposes, session monitoring and to save information on the activities of users visiting the site and may also contain a unique identification code able to track the activities of users browsing the Software itself, for statistical or advertising purposes. While browsing a site, you may also receive cookies from sites or web servers different to the one you are currently at (known as third-partycookies).

Some operations would be impossible without the use of cookies, which in certain cases are technically necessary for the Software to operate.

There are various types of cookies with different characteristics and functions, which can remain on your computer for different periods of time: session cookies, for example, are automatically deleted when the browser is closed; persistent cookies, on the other hand, remain on your device for a predetermined length of time.

According to the applicable legislation, the use of cookies does not always require your consent. In particular, “technical cookies”, i.e. those used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not usually require this consent. In short, these cookies are either essential for the operation of the Software or necessary for the activities requested by the user.

On the other hand, “profiling cookies”, i.e. those aimed at creating user profiles and used to send advertising messages corresponding to the preferences expressed by the users while browsing the net, usually require the user’s prior consent, since they are governed by the applicable regulations.

Types of cookies used by the Platform and optional enable/disable.

Except for third-party cookies, for which you should refer directly to the corresponding disable or enable procedure available via links, the Site uses the following cookies, which can be disabled:

BEE also uses third-party cookies from websites or web servers other than BEE, for the purposes of said third parties, which also include profiling cookies. Note that these third parties, listed below with links to the relevant privacy policies, are usually independent data controllers of the data collected through the cookies they serve, or act as Data Processors for BEE (i.e. they process Personal Data on behalf of BEE).

Details of the cookies sent by BEE through the Software and Website are listed here.

This personal data is processed in accordance with sections 3 (d), (e) and (f) of this Policy.

Cookie settings

You can block or delete technical and functional cookies (entirely or partially) through the specific functions of your browser. However, please note that if you do not consent to the use of technical cookies, it may be impossible to use the Software and the Website, view its contents and use the services it offers. If you disable functionality cookies, the Site may not be available, or some services or functions of the Site may not work properly, and you will have to modify or enter certain information or preferences manually each time you visit the      Software or the Website.

The choices made in reference to the Software cookies will in turn be recorded in a specific cookie. However, this cookie may not work properly in some circumstances: in this case, we recommend you delete unwanted cookies and inhibit their use through the functions of your browsers as well.

Your preferences regarding cookies will be reset if you use different devices or browsers to access the Software.

How to view and modify cookies through your Browser

You can authorize, block or delete cookies (entirely or in part) using the specific functions of your browser. You can get more information on how to set your cookie preferences on your Browser through the following links:

If you do not use any of the browsers listed above, select “cookies” in the relevant section of the guide to find out where your cookie folder is.

You can also manage your choices regarding third-party cookies using on-line Software such as AdChoice or All about cookies.

CAUTION: if you disable technical and/or functionality cookies, the Site may not be available, or some services or functions of the Site may not work properly, and you will have to modify or enter certain information or preferences manually each time you visit the Software.

Deleting Flash cookies

Click the link below to change your Flash cookie settings.

Disabling Flash cookies

Third parties Websites

The Website contains links to other websites that have their own privacy policy. These privacy policies may be different from the one adopted by BEE, which therefore does not answer for third-party sites.

BEE’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

3. Purpose of processing

BEE will use the Personal Data collected through the Digital Properties for the following purposes:

  1. to provide Services such as: registration and access to the Software; help if you lose or forget your      Software login details/password; access to all functions of the Software; to respond to requests for support sent to us through the specific section; to allow you to view accesses to the Software and provide you with any other Service you request; verify your identity and assist you, in case you lose or forget your login / password details for any of the registration services; to reply to your requests for information sent through the Contacts Section and to provide any other Services which you may request (“Provision of the Service”);
  2. to invite you to our events and/or take part in market research and surveys (both on the Software, through the Website and off); to send marketing communications, promotions and advertising, by e-mail, SMS, by phone, by banner, instant messaging and through the official BEE social media pages, as well as for marketing activities in the broadest sense, including prize events and competitions, relating to products and/or services of BEE or third parties (“Marketing”);
  3. to send marketing communications via e-mail regarding products and services similar to those you have purchased (“Soft Opt-in”);
  4. to create your profile through the use of profiling cookies, if you accept, and by collecting and analysing information on your general activities on the Software and/or the Website. We will use your profile to provide you with information on other products and/or services that BEE believes may be of interest to you, and to show you advertisements that may correspond to your tastes. All the algorithms involved in this automated or semi-automated process are regularly tested to ensure that you are not offered products you are not interested in (“Profiling”);
  5. to fulfil legal obligations that require BEE to collect and/or further process certain types of Personal Data (“Compliance”);
  6. to collect information about how the Software is used, and to prevent or identify any abuse in the use of the Software or of the Website or any other fraudulent activity, thereby allowing BEE to defend itself in any legal proceedings (“Abuse/Fraud”).

4. Lawful basis and mandatory or optional nature of processing

BEE applies the following lawful bases for processing your Data for the purposes indicated in preceding paragraph 3:

5. Recipients of Personal Data

Your Personal Data may be shared with the parties listed below (the “Recipients”):

6. Transfers of Personal Data

Since BEE is a US-based company, your Personal Data are processed in the US and may be also shared with Recipients, both internal and external to our Company Group, outside the European Economic Area. BEE ensures that the processing of your Personal Data by such recipients is conducted in compliance with the applicable legislation. The Personal Data that is shared with such Recipients is limited to the categories of Personal Data that are collected by BEE as outlined in section 2 of this Policy.

All transfers are made applying suitable guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate. You can get more information on these matters writing to: privacy@beefree.io.

7. Storage of Personal Data

The Personal Data processed for Providing the Services will be kept by BEE for the time strictly necessary for the aforementioned purpose, i.e. as long as there is a license agreement in place. In any case, given that this Personal Data is processed to provide you with the Service, BEE may store it for a longer period, insofar as it may be necessary to safeguard BEE against possible complaints relating to the Services.

Personal Data processed for Marketing and Profiling purposes will be stored by BEE until you withdraw your consent. If you withdraw your consent, BEE will no longer use your Personal Data for these purposes, but may still store it, insofar as it may be necessary to safeguard BEE against possible complaints concerning this type of processing.

The Personal Data processed for Soft Opt-in purposes will be kept by BEE until you object to such processing using the link at the bottom of each Soft Opt-in e-mail.

Personal Data processed for Compliance purposes will be kept for the period required by the specific obligation or applicable law.

Personal Data processed to prevent Abuse/Fraud will be kept by BEE for the time strictly necessary for the aforementioned purpose and therefore until BEE is required to keep it for disclosure to the judicial Authorities in any legal proceedings.

8. Rights of the Data Subject

You have the right to ask BEE at any time:

you can also:

You can withdraw consent to Marketing e-mails and stop receiving Soft Opt-in using the appropriate links at the bottom of each e-mail received. You can use the same procedure to stop receiving the BEE newsletter, if you previously requested it as a Service.

Your consent to Profiling cookies can be withdrawn using the methods indicated in preceding Paragraph 2.e.

In addition to the above methods, you can also exercise your rights by writing to BEE at the following address: privacy@beefree.io.

In all cases you always have the right to lodge a complaint with the competent Supervisory if you believe the processing of your Personal Data is in breach of the current regulations.

California residents only:

In addition to the above rights, California residents, as defined by the California Consumer Privacy Act (CCPA), have the following rights and, where applicable, are entitled to exercise the following rights before BEE, at any time:

In addition to the above method of exercising your rights, California residents can use the form accessible at the following website address to exercise their General Right to Disclosure and their Right to Disclosure of Sales:

9. Amendments

This Privacy Policy has been in effect since 01/01/2023. BEE reserves to make changes or simply to update the content of the Policy, whether entirely or in part, in the event of changes in the applicable regulations. BEE will inform you of any changes as soon as they are introduced, and they will become binding as soon as published on the Platform. We recommend that you consult this section regularly to view the most recently updated version of the Privacy Policy, to be fully aware of the information we collect and the use we make of it.