Last revised on April 2023
We at Bagel Technologies Inc. (“us“, “we” or “Company“) respect the privacy of our users (each, a “User” or “you“) and are committed to protect the privacy of Users who access, visit, or engage with our website, available at https://www.getbagel.com (the “Website“), our platform, available at: http://app.getbagel.com (“Platform“) and any product, service or feature provided through the Website or the Platform (together with the Website and Platform, the “Services“).
From Whom Do We Collect Personal Information?
- Website Visitors: Individuals who visit our Website and who may volunteer certain contact data (such as their email address) to receive communications from us.
- End-Users: Those who register on their own or on behalf of an entity or organization to use the Platform.
Collection and Storage of Your Personal Information
We collect and use the following types of information about you:
Non-personal Information is non-identifiable information that, when taken alone, cannot be used to identify you. As such, we are not aware of the identity of the user from which the Non-personal Information was collected.
For the avoidance of doubt, if we combine Personal Information with Non-personal Information (e.g. analytics data), the combined information will be treated as Personal Information as long as it remains combined.
Personal Information is information that identifies an individual or that may, with reasonable effort, identify an individual. We gather the following types of Personal Information:
- Name, email address, job function, and other contact information: When you send us an email or contact us via the Website, we collect the Personal Information you provide us. This may include your name, email address and any other information you choose to provide.
- Device information: We collect from our Users specific types of connection details and information with regard to their device, software or hardware that may identify them, such as online identifiers, device unique identifiers (e.g. UDID, MAC address), IP address and geolocation.
- Account Information: When you register to the Platform, we collect your full name, email address, company and job title to identify you and your organization. This Personal Information is required to identify you as our End-User and permit you to access your Account. By providing us with such Personal Information, you represent that you are the owner of such Personal Information.
How We Use Personal Information
In addition to the purposes listed herein, the Personal Information we collect is used for the following purposes:
- Provision of the Services – we will use the Personal Information you provide us for the provision and improvement of our Services, providing customer support and to respond to your queries
- Improving our services – we collect and analyze information about you and your usage of our Services to improve its usability and effectiveness.
- Marketing – according to your communication preferences, we may use your Personal Information in order to send you commercial communication, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions and events, about us and our partners. See more under “Marketing” section.
- Process your job application – if you apply to work at the Company through the Website or email, we will process the Personal Information you provide us.
- Protecting our interests – we may use your Personal Information when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Services and services and protect the rights and property of the Company, its users and/or partners.
- Compliance with legal and regulatory requirements – we may use your Personal Information to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
- Process for other purposes for which we obtain your consent.
With Whom Do We Share The Personal Information We Collect?
- Service providers: we work with service providers that work on our behalf that may need access to certain Personal Information in order to provide their services to us. These companies include those we have hired to provide various services, such as cloud storage or CRM vendors.
- Individuals who work with you: if you register to our Platform, some of your registration details (such as your full name) will be visible to other Users you work with, in order to allow you to interact with each other on the Platform and to use the Services.
- Compliance with laws and law enforcement entities: we may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements. We will only disclose the minimum amount of Personal Information that is required for compliance with such legal requirements.
- Auditors and advisers: we may share your data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for the purpose of ensuring our compliance with regulatory requirements and industry standards.
- Mergers and acquisitions: we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our services.
- Prevention of illegal activities: Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required to comply with our legal obligations.
- As you may otherwise consent from time to time.
Third-parties who we may share your Personal Information with will be required to meet our standards on processing information and security. The Personal Information we provide them will only be provided in connection with the performance of their function.
Why We Use Your Personal Information
Please note that our legal basis for collecting and using your Personal Information will depend on the Personal Information collected and the specific context in which we collect it. We normally collect Personal Information from you only where: (a) we have your consent to do so, (b) where we need your Personal Information to perform a contract with you (e.g. to deliver the service you have requested), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such Personal Information under applicable laws.
In some cases, we may need the Personal Information to protect your vital interests or those of another person.
Where we rely on your consent to process your Personal Information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your Personal Information, you have the right to object.
If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us through the contact details available below.
There are various ways in which you can manage and control your Tracking Technologies settings. For example, you can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). However, please note that certain features of the Website may not work properly or effectively if you delete or disable cookies.
We may use your Personal Information, such as your full name, email address, etc., ourselves or by using our third-party partners for the purpose of providing you with promotional materials, concerning our services.
At any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word “remove” to the contact details listed under the ” How to Contact Us” section below.
Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
Certain jurisdictions provide Users with certain statutory rights to their Personal Information. You may have the right to certain actions to your Personal Information such as:
- To receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with certain supplementary information.
- To receive Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format.
- To request rectification of your Personal Information that is in our control.
- To request erasure of your Personal Information.
- To object to the processing of Personal Information by us.
- To request to restrict processing of your Personal Information by us.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
If you wish to raise a complaint on how we have handled your Personal Information, you can contact us at the contact details available below.
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority.
For How Long Do We Retain the Personal Information We Collect?
We retain the Personal Information that we collect from Users for as long as needed to operate and to provide our Services to you and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). Retention periods will be determined taking into account the type of the Personal Information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Personal Information at the earliest reasonable time. Under applicable regulations, we will keep records containing your Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.
International Transfer (for EEA and UK residents)
Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the EEA and the UK. In these instances, we will transfer your Personal Information only to such countries as approved by the European Commission or the UK Information Commissioner Office as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
How Do We Safeguard Your personal information?
We take great care in implementing and maintaining the security of the Services and of your Personal Information. We employ industry standard procedures to ensure the confidentiality, integrity, and availability of our Users’ data, safety of your Personal Information, and prevent unauthorized use of any such information.
However, we cannot guarantee that hackers or unauthorized personnel will not gain access to Personal Information despite our efforts. You should note that by using our Services, your Personal Information will be transferred through third party infrastructures which are not under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
We do not knowingly collect or solicit Personal Information from anyone under the age of majority (as determined under the applicable laws where the individual resides; “Age of Majority”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Majority. In the event that we learn that we have collected personal information from an individual under the Age of Majority without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Majority, then please contact us through the contact details available below.
Links to Third Party Sites
The Services may contain links to other sites that are not under the Company’s control. These websites have their own policies regarding privacy. You are encouraged to review those policies before visiting such websites. The Company has no responsibility for linked websites, and it provides these links solely for the convenience and information of its Users.
Changes to the Policy
How to Contact Us
Mindspace, Greenwork Business Park
What information we process
In the preceding 12 months, we have collected, and or disclosed the following categories of Personal Information:
|Category of Personal Information Collected||Personal Information Collected||Categories of recipients to whom Personal Information was disclosed|
|Identifiers||Full name, email address, job function, IP address, MAC, UDID||Service Providers|
|Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))||Name, telephone number||Service Providers|
|Internet or Other Electronic Network Activity Information||Cookie and similar online identifiers, information on a consumer’s interaction with a website, application, or advertisement.||Service Providers|
|Geolocation Data (non-precise)||Physical location or movements||Service Providers|
Sources of Personal Information
In the 12 preceding months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:
- Consumer directly.
- Social networks such as LinkedIn.
Purposes for collection and disclosure of Personal Information
Our purposes for collecting Personal Information can be found above, under the section “How we use Personal Information”. Our purposes for disclosing Personal Information to third parties can be found above, under the section “With whom do we share the personal information we collect?”.
Sale and Share of Personal Information
We do not “sell” or “share” (as these terms are defined under California DP Laws) any Personal Information.
User rights under California DP Laws
California DP Laws provide consumers with specific rights regarding their Personal Information. This section describes your rights under California DP Laws and explains how to exercise those rights.
Access to Personal Information
You may request, up to two times each year, that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business or commercial purpose for selling your Personal Information, if applicable.
You have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies.
Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.
Right to Correction
You have the right to request that we rectify inaccurate information about you.
Right to Opt-Out of Selling or Sharing Personal Information
You have the right to opt out of “selling” or “sharing” your Personal Information or from using your Personal Information for automated decision making and profiling.
We do not sell, share, or use your Personal Information for any of the abovementioned purposes.
Right to data portability
You may have the right to obtain your Personal Information in a portable and readily usable format.
Right to non-discrimination
You have the right to be free from any discrimination for exercising your rights under California DP Laws. Should you exercise any of your rights under California DP Laws, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request. However, in some circumstances, for example where you have requested or consented to our services that use your Personal Information to provide the service, we may not be able to provide a service if you choose to delete your Personal Information.
Right to Limit Use of Sensitive Personal Information
We do not engage in uses or disclosures of Personal Information that would trigger the right to limit use of Sensitive Personal Information under California DP Laws.
Exercising Your Rights
You can exercise your rights by submitting a verifiable consumer request to our physical address (as provided – in the “Contact Us” section) or to our email address: email@example.com.
Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.
The request must:
- Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
- 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 the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You can designate an authorized agent to make a request under California DP Laws on your behalf if:
- The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
- You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the California DP Laws.