We respect the privacy rights of users and recognize the importance of protecting information collected about you. This Privacy Policy ("Policy") explains how Bevy Labs, Inc. and its subsidiaries and affiliated companies (collectively “Bevy”, “we“, “our” or “us“) collects, uses, and shares personal information about you and how you can exercise your privacy rights.
If you are located in the European Economic Area ("EEA"), United Kingdom ("UK") or Switzerland (collectively "Europe"), the controller of the personal information that Bevy processes for the purposes described in this Policy is Bevy Labs, Inc.
This Policy applies to the processing of personal information collected by Bevy in the usual course of business, including:
"You" may, depending on the context, be a visitor to our Websites or social media pages; a recipient of our communications or online advertisements; a job applicant; or a Service User.
We may provide additional "just-in-time" disclosures or additional information about our data processing practices. These notices may supplement this Policy or clarify Bevy's privacy practices in the circumstances described or may provide you with additional choices about how Bevy processes your personal information.
This Policy does not apply to websites, products, or services that display or link to different privacy statements or that are operated by companies other than Bevy (including those operated by Bevy’s customers), or to business activities or practices of third parties.
When you engage with our Marketing Activities or use the Bevy Services, you acknowledge that you have read this Policy and understand its content. Your use of the Bevy Services and any dispute over privacy is subject to this Policy, any applicable service terms (including any applicable limitations on damages and the resolution of disputes).
Please read this Policy in full to ensure you are fully informed.
The personal information we collect depends on the context of your interactions with Bevy and the choices you make (including your privacy and browser settings), the Bevy Services you use, your location and applicable law, but can include the following:
Marketing Activities
Information You Provide To Us. We collect information you provide directly to us including when you visit our Websites. For example, when expressing an interest in obtaining information about Bevy or our services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. The personal information we collect may include:
Information We Collect Automatically. When you visit our Websites or engage with our Marketing Activities, like most websites and companies, we use cookies and similar technologies to automatically collect certain technical information from your browser or device. To the extent that this automatically-collected data includes, or is linked to, personal information or personal data, we will treat such data in accordance with this Policy. For further information on cookies and similar technologies please review our Cookie Policy https://www.bevy.com/cookie-notice.
We may automatically collect personal information about you, including:
Information We Collect from Other Sources. In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as our business customers, public databases, marketing partners, financial service providers, affiliate programs, data providers, Social Media Features as noted above, as well as from other third parties.
This information may include mailing addresses, job titles, email addresses, phone numbers, financial information (such as payment, transaction and fraud detection information), intent information (or user behavior information), market segment, IP addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising, event promotion and optimizing our Bevy Services and Marketing Activities. We may combine this personal information with other information we collect about you through our Bevy Services and Marketing Activities.
Bevy Services
Information You Provide to Us. If you are a Service User, you may provide certain personal information to us through the Bevy Services – for example, when you create an account with Bevy, when you consult with customer support or send us an email or communicate with us in any way (for example, to make a support request).
The personal information we collect may include:
Information We Collect Automatically. When you use or interact with the Bevy Services, we automatically collect or receive certain information through the Bevy Services (for example in log files) and through other technologies (such as cookies) about your device and usage of the Bevy Services.
To the extent that this automatically-collected data includes, or is linked to, personal information or personal data, we will treat such data in accordance with this Policy. For further information on our use of cookies and similar technologies please review our Cookie Policy https://www.bevy.com/cookie-notice.
We may automatically collect personal information about you, including:
Information We Process on Behalf of our Business Customers. We process certain personal information about Service Users on behalf of our business customers (where we act as a data processor or service provider on their behalf). This personal information may include usage data such as first name, last name, email, profile picture and user ID from the social platform used to create an account. As described above, in most cases, we only process this personal information on behalf of and as instructed by our business customers (the data controllers of the personal information).
However, where permitted by the relevant business customer and applicable law, we may leverage certain personal information collected through the operation of the Bevy Services for our internal research and development purposes to develop and improve our Marketing Activities and the Bevy Services (for which we will be a data controller). For these purposes, we only use personal information in a de-identified form that does not specifically identify any particular Service User (for example, by reference to their name or other identification information). For example, we may leverage de-identified information to train our models and algorithms, to make more consistent measurements and therefore to improve the functionality and accuracy of our Marketing Activities and the Bevy Services.
We use and process the personal information identified above for the purposes and on the legal bases identified below.
Marketing Activities
Bevy Services
If you have questions about the legal basis for processing or want to find out more, please contact us using the details at the end of this Policy in the Section "Contacting Us" below https://help.bevy.com/.
We do not sell or share personal information about you with third parties except as described below. We may share personal information about you:
We may also share aggregated or de-identified usage data with third parties to help us perform analysis and make improvements. Additionally, we may share anonymous usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends in the use of the Bevy Services.
Any personal information or other information you choose to submit in communities, forums, blogs, or chat rooms may be read, collected, and used by others who visit these forums, depending on your account settings.
For further information on the recipients of your personal information, please contact us (see the " Contacting Us" section below).
Personal information we collect may be stored and processed in your region, in the United States or in any other country where we or our affiliates, subsidiaries or service providers maintain facilities. Bevy is a US-based company. Our group affiliates and third-party service providers and partners operate around the world. Some jurisdictions have data protection laws that are different from the laws where you are located (and, in some cases, may not be as protective), and may be subject to access requests from governments, courts, or law enforcement according to applicable laws. We endeavor to safeguard your personal information in accordance with this Policy and the requirements of applicable laws.
Where we are a party to a transfer of personal information originating in Europe to third countries and territories outside of Europe which have been formally recognized as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” and “adequacy regulations” from the European Commission, Swiss and UK authorities. This includes relying on the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework.
Where the transfer is not or cannot be subject to an adequacy decision, we take appropriate safeguards to ensure that your personal information will remain protected in accordance with this Policy and applicable laws. These safeguards include implementing the European Commission’s Standard Contractual Clauses as issued on 4 June 2021 under Article 46(2) GDPR for transfers originating in the EEA and Switzerland; and the UK Addendum under Article 46(2) of the UK GDPR for the transfer of data originating in the UK.
Our Standard Contractual Clauses entered into by our group companies and with our third-party service providers and partners can be provided upon request. Please note that some sensitive commercial information will be redacted. If you have any questions or concerns related to international data transfers, please contact us via the contact details set out below.
EU-US Data Privacy Framework, UK Extension and Swiss-US Data Privacy Framework
Bevy Labs, Inc. (for the purposes of this section, “Bevy”, “we”, or “us”) has certified to the U.S. Department of Commerce that we adhere to: (i) the EU-U.S. Data Privacy Framework Principles with regards to the processing of personal information received from the EEA in reliance on the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), (ii) the UK Extension to the EU-U.S. DPF with regards to the processing of personal information received from the UK (and Gibraltar), and (iii) the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) with regards to the processing of personal information received from Switzerland in reliance on the Swiss-U.S. DPF (collectively, the "DPF" and the “DPF Principles”).
The Federal Trade Commission has jurisdiction over our compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. If there is any conflict between the terms in this Policy and the DPF Principles, the DPF Principles shall govern. To learn more about the DPF, and to view our certifications, please visit https://www.dataprivacyframework.gov/s/.
The types of personal information we receive in the United States, as well as the purposes for which we collect and use it, are set out in Sections 3 and 4 above. We will give you an opportunity to opt out where personal information we control about you is to be disclosed to an independent third party or is to be used for a purpose that is materially different from those set out in this Policy. If you otherwise wish to limit the use or disclosure of your personal information, please contact us via the contact details set out below.
Information about the types of third parties to which we disclose personal information and the purposes for which we do so are described in Section 5 above. If we have received your personal information in the United States and subsequently transfer that information to a third party acting as an agent, and such third party agent processes your personal information in a manner inconsistent with the DPF Principles, we will remain liable unless we can prove we are not responsible for the event giving rise to the damage.
Please note that, under certain circumstances, we may be required to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you are located in Europe, you have the right to request access to the personal information that we hold about you and request that we correct, amend, or delete it if it is inaccurate or processed in violation of the DPF Principles. If you would like to exercise these rights, please write to us at the contact details provided below. We may request specific information from you to confirm your identity and we will respond to your request in accordance with the DPF Principles and applicable data protection laws. You may also opt-out of receiving marketing communications from us by writing to us at the contact details provided below or by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.
Bevy commits to resolve complaints about our collection or use of your personal information. European individuals with inquiries or complaints regarding our handling of personal information received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Bevy us using the contact details provided below. We will investigate and attempt to resolve any DPF-related complaints or disputes within forty-five (45) days of receipt.
If you have an unresolved DPF complaint that we have not addressed satisfactorily, we have committed to refer unresolved DPF complaints to JAMS which is an independent dispute resolution body located in the United States. These services are provided free of charge to you. For more information or to submit a complaint, please visit https://www.jamsadr.com/file-a-dpf-claim.
Under certain conditions, you may be entitled to invoke binding arbitration for the resolution of your complaint. To find out more about the DPFs's binding arbitration scheme please see https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf.
We reserve the right to amend this section from time to time consistent with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF requirements.
Bevy takes reasonable precautions, including organizational, technical, and physical measures, to help safeguard your personal information against accidental or unlawful destruction, loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions.
To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been compromised in any way. In addition, always log out and close your browser when you finish your session. Please note that we will never ask you to disclose your password to us. If you have any questions about the security of our Websites, please contact us (see "Contacting Us" below).
8. How Long we Store your Personal Information
We retain your personal information where we have an ongoing legitimate business need to do so and for a period of time consistent with the original purpose as described in this Policy.
We determine the appropriate retention period for personal information on the basis of the amount, nature and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation). For example, we retain personal data as needed to maintain appropriate business and financial records, protect our legal interests, resolve disputes, or comply with legal or regulatory requirements. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize your personal information or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information using appropriate security measures and take appropriate steps designed to isolate it from any further processing until deletion is possible.
If you request account deletion, we will delete your information as set forth in the “Your Privacy Rights and Choices” section below.
Bevy provides ways for you to access and delete your personal information as well as exercise other rights that give you certain control over your personal information.
All users
Account Information. You may update, correct, or delete information about you at any time by logging into your product account and modifying your information, or by emailing us at privacy@bevy.com. We will retain your personal information for the period necessary to fulfil the purposes outlined in this Policy. If you wish to deactivate your product account, you can do so yourself in your user account settings.
Upon request, Bevy will provide you with information about whether we hold or process your personal information that we are aware of. To request this information, contact us at privacy@bevy.com.
Promotional and Newsletter Communications (Email Subscriptions). You may opt out of receiving promotional and newsletter emails from Bevy at any time by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing privacy@bevy.com with your specific request. We make every effort to promptly process all unsubscribe requests. If you opt out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the Bevy Services or those about your account or our ongoing business relations.
Cookies. You can modify your cookie preferences in our [Cookie Preference Center / Cookie Settings] or on your browser, but if you delete or choose not to accept some of the cookies, you may lose certain functionality and features.
European residents and visitors
If you are a resident of or visitor from Europe, where we are acting as a data controller, you may have the following rights with regard to the personal information we control about you:
To make a request under the GDPR or to exercise any other data rights under European law, contact us via email at compliance@bevy.com. Please include your full name along with why you are writing so that we can process your request in a timely manner.
Our Websites and Bevy Services, including the Bevy blog, may contain links to third-party websites or resources, including websites and services not operated by Bevy. The privacy practices of these websites and services will be governed by their own policies. We make no representation or warranty as to the privacy policies of any third parties, including the providers of third party applications. If you are submitting information to any such third party through our Websites and Bevy Services, you should review and understand that party’s applicable policies, including their privacy policy, before providing your information to the third party. Please contact those third parties directly if you have any questions or concerns about their privacy policies and practices.
The Bevy Services and our Marketing Activities are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us at privacy@bevy.com. Please note, if you are under the age of 16, you may not use our website, products, or services.
Each time you use our Websites or our Bevy Services or engage with our Marketing Activities, the current version of this Policy will apply. We may change this Privacy Policy from time to time as our Bevy Services and Marketing Activities change and privacy or data protection law evolves. If we make any changes, we will revise the "Last Updated" date at the beginning of this Policy and, in some cases if we make material changes, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to review our Policy whenever you access the Websites or Bevy Services to stay informed about our practices.
Any questions or concerns about this Policy, including if you need to access this Policy in an alternative format, or if you wish to lodge a complaint about our privacy practices, should be addressed to privacy@bevy.com or to:
Bevy Labs, Inc.
265 Cambridge Ave #60608
Palo Alto, CA 94306
Because email communications are not always secure, please do not include sensitive information in your emails to us.