Last Updated: January 21, 2020

BigConnect. (“BigConnect”, “We”, “Us” or “Our”) is the data controller of any information collected on or through this Web site. We are also the controller of personal data associated with our current, past, and prospective business clients’ (“Client”, “Clients”) interactions with us and our services.

This Privacy Policy explains how information about you is collected, used and disclosed by BigConnect, Inc. This Privacy Policy applies to information we collect when you use our website www.bigconnect.io and BigConnect’s products and services (collectively, the “Services.”) This Privacy Policy also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal data.

Note that we are a processor for any personal data collected through our services. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged BigConnect, and our Client’s privacy statement applies to their use of the data. To the extent that BigConnect processes any personal data as data processor on behalf of the Client as data controller pursuant to any agreement entered into between BigConnect and the Client, the terms of the Data Protection Addendum located here shall apply. The Client may complete, sign and return the Data Protection Addendum to privacy@bigconnect.io.

As a global company, BigConnect may process data in multiple countries, including in the United States. BigConnectparticipates in and has certified its compliance with the EU – U.S. Privacy Shield Framework. BigConnect is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework (the “Framework”), to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov

BigConnect is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. BigConnect complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

We may change this Privacy Policy from time to time. If we make material changes, we will notify you or our Client by revising the date at the top of the policy, and in some cases, we may provide you with more prominent notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

Information Collection

Information you provide to us. We collect information you provide directly to us, from public sources and from third parties. For example, we collect information when you create an account, use the Services, fill out a form, request customer support or otherwise communicate with us. We may collect your information from public sources, in person meetings or events. We may also receive your information from third parties, if you have provided your consent to the third party. The types of information we may collect include your email address, postal address and other contact or identifying information you choose to provide.

Information we collect automatically when you use the Services

When you access or use our Services, we automatically collect information about you, including:

Following are additional details about information we may collect from or about you.

Information we collect from other sources

With written consent, we may conduct background checks on our potential employees. If we do, the only information that we append is the result (pass or fail) of that background check. This helps us to evaluate potential candidates for employment.  We don’t append personal data on results of the background check.

We use information about you for various purposes, including to:

Generally, BigConnect processes data we control in order to respond to your requests and manage our business relationship. We may get your consent for activities like direct marketing, and to post your information publicly on blogs or share your information with third parties. BigConnect also relies on the legal basis of legitimate interest for some marketing activities, and for activities like security and fraud prevention, analysis of activities, trends and your opinions to improve our product, and in some cases sharing and coordination with commercial business partners to help you fulfill your business needs. You have the right to withdraw any consent you have given, and object to any processing done under legitimate interest. Contact us for more information about your rights.

We may share personal data about you as follows:

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Frames

Some of our pages utilize framing techniques to serve content to/from our partners while preserving the look and feel of our website. Please be aware that you are providing your personal data to these third parties and not to www.bigconnect.io. We suggest that you review the privacy statement of any applicable third parties before providing personal data.

Third-party analytics and advertisements

We allow third parties to serve advertisements on our behalf across the Internet and to provide analytics services. These third parties may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by BigConnect and third parties to, among other things, analyze and track data, deliver advertising based upon your browsing activities and interests and to better understand your use of the Services. If you wish to opt out of interest-based advertising click here (or if located in the European Union click here). Please note you will continue to receive generic ads.

It is important to note that BigConnect will not sell your personal information.

BigConnect takes reasonable measures to help protect personal data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us. Please keep in mind that no security measures are 100% effective, and we encourage you to regularly review your accounts for suspicious activity and carefully guard your credentials.

BigConnect retains your personal data according to our data retention and deletion schedule, with the commitment to delete or anonymize your personal data once our legitimate business or legal needs end.

Promotional communications

We will periodically send you free newsletters and e-mails that directly promote the use of our site or the purchase of our products or services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us – you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by submitting a request. Should you decide to opt-out of receiving future mailings, we may share your e-mail address with third parties to ensure that you do not receive further communications from third parties. Despite your indicated marketing e-mail preferences, we may send you transactional emails and notices of any updates to our Terms of Service or Privacy Policy.

Account or Profile Information
Upon request BigConnect will provide you with information about whether we hold any of your personal data. You may ask us to update, correct or delete information about you at any time. If you wish to delete or suspend your account, please contact us, but note that we may retain certain information as required by law or for legitimate business purposes. Also, if you have become aware that a profile has been created about you without your consent or knowledge, you may contact us to request deletion of that said account.  We may also retain cached or archived copies of your information for a certain period of time. We will respond to your request without undue delay within 30 days.

You can also ask about:

Finally, you can ask us not to collect or use your personal data for certain purposes (including for purposes that are materially different from the purposes for which it was originally collected), you can ask us to delete your personal data, or you can ask us to either refrain from sharing your information with or specifically ask that we do provide your personal data to a third party.

Depending on which laws apply to your personal data, we may only be able to do some of these things for you. If you request one of these things and we refuse to do it, we will explain the reason for our refusal and any recourse you may have.

We will respond to your request without undue delay within 30 days. We reserve the right to take reasonable steps to verify your identity prior to granting access or processing changes or corrections

To address any privacy or security questions or concerns, or to make any of these requests, contact us with details about your request.

How can I lodge a complaint?

We commit to investigating and resolving complaints about our collection or use of your personal data. To make a complaint, contact us.

Clearly state the following to help us address the issue effectively:

For European Union residents

If you are in the EU, and if you are not satisfied with our resolution of your complaint, you may complain to the Information Commissioner’s Office (ICO). We commit to cooperating with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel or the FDPIC with regard to personal data transferred from the EU. For the purposes of the Privacy Shield, we are subject to the investigatory and enforcement powers of the Federal Trade Commission. In some conditions, you may be able to invoke binding  arbitration to resolve your complaint where your personal data has been transferred to and processed in the United States.

For United States residents

If you are not satisfied with our resolution of your complaint, you can make a privacy complaint to the Federal Trade Commission or you can make a consumer reporting complaint to the Consumer Financial Protection Bureau.

For Canadian residents

If you are not satisfied with our resolution of your complaint, you may be able to make a complaint to one of the following regulatory agencies. Upon resolution of your complaint, we will let you know which of these, if any, may apply to your situation.

We aim to resolve all issues in a timely manner, or as mandated by local law, but if this is not possible because a more detailed investigation is required, we will keep in regular contact with you to ensure that you are kept informed of the resolution of your matter.

This website is not intended for anyone under the age of 16 years. If you are younger than 16, you may not register with or use this website.

Information Related to Data Collected for our Clients:

BigConnect collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and have a concern or request related to your personal data, please contact the Client that you interact with directly. We may transfer personal data to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

Access and Retention of Data Controlled by our Clients:

BigConnect acknowledges that you have the right to access your personal data. BigConnect has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the BigConnects Client (the data controller). If our Client requests that we remove data we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. BigConnect will retain this personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

BigConnect Data Policy

Last Updated: January 24, 2018

This Data Policy (the “Policy”) describes BigConnect’s policy for handling, storing, and otherwise treating certain types of data of BigConnect’s customers (each, a “Customer”), including data associated with individual users and employees of Customer organizations, in each case pursuant to a Customer Agreement (as defined below).  “BigConnect” means BigConnect, Inc. and its subsidiaries and affiliates.

Additional policies that apply to specific BigConnect Products and Services can be found at the end of this Policy, in the section entitled “Service-Specific Terms.”

BigConnect collects information that a Customer or other data sources send to BigConnect as part of such Customer’s use of BigConnect Products and Services.  This data is addressed in three categories, “Transaction Data”, “Account Data” and “Personal Data”, each as defined below.

BigConnect understands the sensitive nature of the data that Customer or Customer’s organization may provide while using BigConnect Products and Services.  BigConnect will maintain commercially reasonable administrative, physical and technical safeguards designed for the protection, confidentiality and integrity of Customer’s Transaction Data and Account Data.

Data Use by BigConnect

Access. BigConnect places strict controls over its employees’ access to Customer’s Transaction Data and Account Data that resides in the BigConnect Products and Services, and is committed to ensuring that Customer’s Transaction Data and Account Data is not used by anyone who should not have access to it.  The operation of the BigConnect Products and Services requires that some employees have access to Customer systems which store and process Customer’s Transaction Data and Account Data. For example, in order to diagnose a problem Customer is having with BigConnect Products and Services, the BigConnect support team may need to access Customer’s Transaction Data.  These employees are prohibited from using these permissions to view Customer’s Transaction Data unless it is necessary to do so.

Use of Transaction Data.  BigConnect will treat Transaction Data as confidential and will use it only to: (i) facilitate operation of the BigConnect Products and Services; (ii) enhance the use of the BigConnect Products and Services and its related web pages; (iii) perform internal tracking to improve BigConnect Products and Services; (iv) analyze the extent to which Customers use BigConnect Products and Services; (v) enable BigConnectto contact its Customers; (vi) process, bill and invoice Customer’s transactions for BigConnect Products and Services usage; (vii) make backups in order to prevent data loss; and (viii) comply with the law or a binding order of a governmental body.   This permission includes allowing us to use third-party service providers in the operation and administration of BigConnect Products and Services and the rights granted to us are extended to these third parties to the degree necessary in order for BigConnect Products and Services to be provided. The Privacy Policy does not apply to Transaction Data.

Use of Account Data.  BigConnect will only use Account Data in accordance with the Privacy Policy, and Customer consents to such usage.

Feedback.  If any Customer users provide BigConnect with any feedback, support tickets, reported defects, usability enhancements, feature requests or suggestions regarding BigConnect Products and Services, Customer grants BigConnect an unlimited, irrevocable, perpetual, free license to use any such feedback or suggestions for any purpose without any obligation to Customer.

Retention of Transaction Data and Account Data

Data collected by BigConnect as part of diagnostic bundles will be retained for a period of 12 months.  All other Transaction Data and Account Data may be retained no longer than as permitted by governing law, but in no event longer than for the life of the related BigConnect product + 10 years.

Incident Management and Response

In the event of a security breach involving BigConnect Products and Services, BigConnect will promptly notify each affected Customer of any unauthorized access to any of such Customer’s Transaction Data or Account Data that was stored in BigConnect Products and Services.  BigConnect has internal incident management procedures in place to handle such an event.

Product Security Practices

New features, functionality, and design changes go through a security review process facilitated by BigConnect’s security team.  The security team works closely with development teams to resolve any additional security concerns that may arise during development.

BigConnect’s current Privacy Policy is incorporated into this document and includes important terms regarding BigConnect’s handling of Personal Data.  The sections above relating to Incident Management and Response and Product Security Practices also apply to Personal Data.

Customer Account and Account Data

To access certain BigConnect Online Services, Customer may be asked to create a BigConnect account associated with a valid e-mail address (a “Customer Account”).  Customer may only create one account per email address. Customer is responsible for: (i) maintaining the confidentiality of the Account Data, (ii) monitoring and controlling which end users have access to the Customer Account; and (iii) all activities that occur under the Customer Account, regardless of whether the activities are undertaken by Customer, Customer’s employees or a third party (including Customer’s contractors or agents).  Except to the extent caused by BigConnect’s breach of this Data Policy, BigConnect and its Affiliates are not responsible for unauthorized access to the Customer Account. Customer will contact BigConnect immediately if Customer believes an unauthorized third party may be using the Customer Account or if Customer’s Account Information is lost or stolen.

Acceptable Use

Customer must not: (i) use, or encourage, promote, facilitate or instruct others to use, BigConnect Products and Services for any illegal, harmful or offensive use, or to transmit, store, display, distribute or otherwise make available content that is illegal, harmful, or offensive; (ii) use BigConnect Products and Services to violate the security or integrity of any network, computer or communications system, software application, or network or computing device; (iii) make network connections to any users, hosts, or networks unless Customer has permission to communicate with them; (iv) use BigConnect Products and Services to transmit spam, bulk or unsolicited communications; or (v) use BigConnect Products and Services to collect and store personally identifiable information about any person unless specifically authorized by such person.

Transaction Data, Account Data and Personal Data

Customer is solely responsible for the creation, operation and maintenance of Transaction Data, Account Data and Personal Data. For example, Customer is solely responsible for:

Customer agrees that its Transactional Data, Account Data and Personal Data will not include information regulated under the International Traffic in Arms Regulations (U.S. government regulations addressing defense-related articles and services).

Customer agrees not to upload, post or otherwise transmit to BigConnect any Transaction Data that: (a) is inaccurate, harmful, obscene, pornographic, defamatory, racist, violent, offensive, harassing, or otherwise objectionable; (b) includes unauthorized disclosure of personally identifiable information or other confidential information; (c) violates or infringes any third party intellectual property rights; or (d) contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment.  BigConnect reserves the right to edit or remove Transaction Data that violates this Policy.

By providing Transaction Data, Customer represents and warrants to BigConnect that Customer owns or otherwise possesses all intellectual property rights and other rights necessary to provide such Transaction Data and to permit others to make use of such Transaction Data.

Security and Backup

Customer is responsible for taking its own steps to maintain appropriate security, protection and backup of Transactional Data, Account Data and Personal Data, which may include the use of encryption technology or anonymization to protect such data from unauthorized access.

Customer Data

BigConnect Products and Services that store or process Customer Data are either located on a third-party hosting site or on Customer’s own servers.  As such, BigConnect has no liabilities or obligations with respect to Customer Data under this Data Policy.

“Account Data” means information about Customer that Customer provides to BigConnect in connection with the creation or administration of its BigConnect account. For example, Account Data includes names, user names, phone numbers, email addresses and billing information associated with Customer’s BigConnect account.

"BigConnect Products and Services" means any of BigConnect’s products and software to which Customer may have subscribed under the terms of a Customer Agreement, including but not limited to BigConnect Manager, BigConnect Enterprise, BigConnect Live, BigConnect Express, BigConnect Altus Director, any BigConnect Online Services, any trial software, and any software related to the foregoing.

“Customer Agreement” means the separate agreement between Customer and BigConnect governing Customer’s use of the BigConnect Products and Services.

“Customer Data” means any of Customer’s originating data that might be stored in nodes and accessed by BigConnect’s software or other third-party software.

“Personal Data” means data that can identify an individual or that is associated with the identity of an individual.

“Transaction Data” means all data that is (i) input into BigConnect Products and Services by Customer or its end users, (ii) generated by BigConnect’s systems as a result of Customer’s or its end users’ use of the BigConnect Products and Services, or (iii) data that is generated for troubleshooting and diagnostics, in each case that is transmitted to BigConnect. Transaction Data does not include Customer Data.

BigConnect Navigator Optimizer and Workload Analytics

Data Use.  BigConnect’s Navigator Optimizer service (“Optimizer”) and Workload Analytics service (“Workload Analytics”) do not collect or store any Personal Data or Customer Data.  These services may collect and/or store certain types of Transaction Data such as Customer’s queries or workload information (“Analytics Data”). While Analytics Data is confidential information and will be protected pursuant to the provisions in this policy that apply to Transaction Data, Optimizer and Workload Analytics are not databases of record for the storage of Analytics Data.  Retention of this Analytics Data is not BigConnect’s responsibility.

Availability.  BigConnect is committed to making Optimizer and Workload Analytics highly-available services that Customers can count on.  To the extent feasible, BigConnect’s infrastructure runs on systems that are fault-tolerant, for failures of individual servers.  BigConnect’s operations team tests disaster-recovery measures regularly and staffs a team to quickly resolve unexpected incidents.  However, at this time BigConnect makes no uptime or availability guarantees with respect to Optimizer or Workload Analytics or retention of Analytics Data.