Last Updated: March 2023
We gather various types of Personal Data from our Members, as explained in more detail below, and we use this Personal Data internally to personalize, and provide our Services. For example, we may use data to allow you to set up a member account and profile, to contact you and to fulfill your requests for certain Products and/or Services. In certain cases, we may also share some Personal Data with third parties, as described below.
WHAT INFORMATION DOES BOND COLLECT?
Bond collects Personal Data that you provide directly to us and that is automatically collected in connection with your use of our Services.
Personal Data may include (but is not limited to): Member info/data, usage data/info, in-app activity info, command center engagements, payment data (Bond uses third-party payment processors), and more. This information is collected when you share the following with us: Name (first, last); Email; Phone Number; Country of Residence; Personal PIN code (which we store locally in the Company Application at the device/smartphone level. We will not store in our servers); Device default language; Audio and video of you (e.g. related to calls made through the Services); Home Address.
In addition, we may collect the User profile data you choose to volunteer to Company (please note: Company does not verify for accuracy) including, without limitation: (1) Eye Color; (2) Hair Color; (3) Other information from Command Center during onboarding: (i) Height; (ii) Weight; (iii) Medical and health conditions (if known); (iv) Medications (if known); (v) Blood Type; (vi) Default language preference for communication with TG; (vii) Second language preference; (4) Date of Birth; (5) Information we gather about family, emergency contacts or other personal contacts you choose to share with Company: (i) Name (first, last); (ii) Phone Number; (iii) Relationship to you; (iv) Email; (6) Posts, data and images that you share; (7) Data from hardware devices; (8) Location Information (e.g. Home or Office).
We receive and store any information that you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Data such as your email address.
We may communicate with you if you’ve provided us with the means to do so. For example, if you’ve given us your email address, we may email you about your use of our Services. If you do not want to receive certain forms of communications from us, please indicate your preference by [email protected].
Information we receive from third party sources: Some third parties, such as our business partners and service providers, provide us with Personal Data about you, including (without limitation):
Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following data: IP address; Device identifiers; Web browser information; Usage information; Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.); Log data (e.g. access times, hardware and software information); Language preference; data about the phone or other device you use to access our services; Real time location via GPS (via permission access to location); Audio (via permission access to microphone), Video (via permission access to video camera), as permissions the member chooses to provide to Company; Log data (e.g. access times, hardware and OS software information); Cellular connectivity information; Pictures (via permission access to the member’s camera library); Battery status information; Data from smartphone’s sensors (accelerometer, magnetometer, others); Recordings of audio and or video Calls a member had with Company Command Center personnel; Recordings of audio and or video Calls a member had with Authorities if the connections were made via the Company Application; Notes/logs the Command Center personnel might have collected when assisting a member with a live case; Historical records about a member’s location (location history only stored when using the Track Me On The Go or Security Check modules and only 7 days are retained on a rolling basis).
HOW DO WE USE AND PROCESS YOUR PERSONAL DATA?
The Company processes your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.
The Company shall not process Personal Data unless there is a legal basis for such processing. The legal bases according to which the Company may process Personal Data are as follows:
Your consent that the Company will process Personal Data about you for one or more specific purposes. By way of example, for the purpose of sending marketing materials to you.
Where the legal basis for the processing of the Personal Data about you is consent, you may at any time withdraw your consent for the purposes for which you provided your consent by sending a notice to the following email address: [email protected].
Where you withdraw your consent for the processing of Personal Data about you, we might not be able to provide you with some or all of the Products and/or Services (including, but no limited to, the Application) you requested or in the form intended to be provided to you, and you will have no claim in respect of that.
Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract. By way of example, in order to allow you to install and use the Application.
Processing is necessary for the purposes of the legitimate interests pursued by the Company. By way of example, for the purpose of improving our Products and/or Services (including, but not limited to, the Application), or for the exercise or defense of legal claims.
Whenever the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, the processing is conditional upon such interests not overridden by your interests or fundamental rights and freedoms which require protection of Personal Data about you. At any time, you may approach us by sending a notice to the following email address: [email protected], in order to receive information concerning the review performed by us in order to reach the conclusion that we may process the Personal Data about you on account of such processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
The following list outlines the purposes for which we may process Personal Data about you and the legal basis for any such processing:
|1||In order to install and register as an account holder to the Application We will process your Personal Data in order to allow you to install the Application and open an account.||Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.|
|2||In order to allow us to provide you with as well as use our Products and/or Services (including, but not limited to, the Application) Whenever you request to use our Products and/or Services (including, but not limited to, the Application), We will process the Personal Information required for Us to perform such requests.||Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.|
|3||In order to contact you for the purpose of operational requirements In some circumstances, we will contact you in order to update you in respect of certain operational matters; for instance, where a certain aspect of our Products and/or Services (including, but not limited to, the Application) is changing. In these circumstances, we will need to use Personal Data about you accordingly.||Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.|
|4||In order to respond to your queries, requests and/or complaints, and to provide you with customer support services Processing of Personal Data about you is required in order to respond to queries you have concerned our Products and/or Services (including, but not limited to, the Application), and in general to provide you with customer support services.||Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.|
|5||In order to perform and maintain various activities supporting the offering and provision of our Products and/or Services (including, but not limited to, the Application) Such activities include back-office functions, business development activities, technical functionality and security, strategic decision making, oversight mechanisms, etc.||Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.|
|6||In order to protect Our and third parties’ interests, rights and assets, including initiation or exercise or defense of legal claims We may process Personal Data about you in order to protect the interests, rights and assets of ours and of third parties, according to any law, regulation and agreement, including any of our terms and conditions and policies.||Processing is necessary for the purpose of the legitimate interests pursued by the Company or by a third party.|
|7||In order to improve our Products and/or Services (including, but not limited to, the Application) We may aggregate your Personal Data and then use that aggregated data in order to improve our Products and/or Services. Any such aggregated data used for this purpose will be aggregated in such a manner so as to prevent the re-identification of you personally. Only Personal Data collected from you in conjunction with your use of the Product and/or Services will be processed in this manner – i.e., no Personal Data will be collected from you for the primary or exclusive purpose of improving our Products and/or Services. Such aggregated data may be provided to your employer to enable your employer to better understand whether its employees are using the Products and/or Services and, if so, to what extent.|
Without limiting the foregoing and notwithstanding any rights of publicity, privacy or otherwise (whether or not statutory) anywhere in the world, and without any further compensation or right to review or approve any use permitted herein, we may and are hereby authorized to use audio and/or visual recording media (and other data) made in compliance with this Policy (including my voice, image, likeness and appearance) in whole or in part, with or without modification, in connection with providing the Command Center service.
WILL BOND SHARE ANY OF THE PERSONAL DATA IT RECEIVES?
We do not rent or sell your Personal Data in personally identifiable form to anyone. We may disclose your Personal Data to others as described in this section. For Members with accounts located in the European Economic Area (EEA), all processing of Personal Data is performed in accordance with privacy rights and regulations following the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR“).
Service Providers: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. For example, we may use a data hosting service provider to store your information and make it available to use for our Services. Unless we tell you differently, our agents do not have any right to use the Personal Data we share with them, beyond what is necessary to assist us.
Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Data could be one of the assets transferred to or acquired by a third party.
Transfers Of Personal Data To A Third Country Or An International Organization
Personal Data about you may be transferred to a third country (i.e., jurisdictions outside the EEA) or to international organizations. In such circumstances, the Company shall take any reasonable efforts to safeguards aimed to ensure the protection of Personal Data about you and provide that enforceable data subject rights and effective legal remedies for data subjects are available.
These safeguards and protection will be available if any of the following are met:
You may request the Company to be provided with details concerning the safeguards employed by it to protect the Personal Data about you which is transferred to a third country or an international organization, by sending an email to the following address: [email protected].
IS PERSONAL DATA ABOUT ME SECURE?
We implement appropriate technical and organizational and technical measures to ensure an appropriate level of security to Personal Data taking into account the risks that are presented by processing, in particular from an accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed. Notwithstanding, any transfer of Personal Data via the internet cannot be fully secured. Therefore, the Company cannot ensure the protection of Personal Data about you when transferred via the internet to Us (including, but not limited to, via the Application).
Your account is protected by a password for your privacy and security. If you access your account via a third party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorized access to your account and Personal Data by selecting and protecting your password and/or other sign-on mechanisms appropriately and limiting access to your device by signing off after you have finished accessing your account.
We endeavor to protect the privacy of your account and other Personal Data we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of member information at any time.
We may be required, due to legal or other obligations outside our control, to transfer Personal Data about you to third parties, such as public authorities. In such circumstances, we have limited control over the level of protection provided to the Personal Data about you by such third parties.
Your Rights in respect of The Personal Data
You are entitled to the following rights in respect of the Personal Data about you. The exercise of such rights will be via sending an email requesting to exercise your right to the following email address: [email protected].
Right of access
You have the right to receive from the Company confirmation as to whether or not Personal Data about you is being processed, and, where that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organizations; (4) where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request or restriction of processing of Personal Data about you or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) where the Personal Data is not collected from you, any available information as to its source; (8) the existence of profiling; and (9) where Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards relating to the transfer.
The Company shall provide a copy of the Personal Data undergoing processing and may charge a reasonable fee for any further copies requested by you. Where you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form.
The right to obtain a copy of the Personal Data shall not adversely affect the rights and freedoms of others, and therefore if the request will harm the rights and freedoms of others, the Company may not fulfill your request or do so in a limited manner.
Right to rectification
You have the right to obtain from the Company the rectification of inaccurate Personal Data about you. Taking into account the purposes of the processing, you have the right to have incomplete Personal Data about you completed, including by means of providing a supplementary statement.
Right to erasure
You have the right to obtain from the Company the erasure of Personal Data about you where one of the following grounds applies: (a) the Personal Data is no longer necessary in relation to the purpose for which it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal ground for the processing; (c) you object at any time, on grounds relating to your particular situation, to processing of the Personal Data which is based on the legitimate interests pursued by Us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of the Personal Data for direct marketing purposes; (e) the Personal Data has been unlawfully processed; (f) the Personal Data has to be erased for compliance with a legal obligation in European Union or Member State law to which the Company is subject.
This right is not applicable to the extent that the processing is necessary: (a) for compliance with a legal obligation which requires processing by European Union or Member State law to which the Company is subject; or (b) for the establishment, exercise or defense of legal claims.
Right of restriction of processing
You have the right to obtain from the Company restriction of processing of Personal Data about you where one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling the Company to verify the accuracy of the Personal Data; (b) the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead; (c) the Company no longer needs the Personal Data for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims; (d) where the processing of the Personal Data is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, unless We demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Where processing of Personal Data about you has been restricted following your request, such Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
Right to data portability
You have the right to receive the Personal Data about you, which you have provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit such Personal Data to another controller, where: (a) the processing is based on your consent or on a contract to which you are a party; and (b) the processing is carried out by automated means.
In exercising your right to data portability, you have the right to have the Personal Data about you transmitted directly from the Company to another controller, where technically feasible. The exercise of your right to data portability is without prejudice to your and the Company’s rights under your right to erasure. In addition, the right to data portability shall not adversely affect the rights and freedoms of others.
Right to object
You have the right to object at any time, on grounds relating to your particular situation, to processing of Personal Data about you which is based on the legitimate interests pursued by the Company or by a third party, including profiling based on such legitimate interests; in such case, we shall no longer process the Personal Data about you unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
You have the right to object at any time to the processing of Personal Data about you for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing.
Right to withdraw consent
You may withdraw your consent provided to us for the purpose of processing Personal Data about you at any time, without affecting the lawfulness of processing based on your consent before its withdrawal. Please note that in a case where you will withdraw your consent, we may not be able to provide you with some of our Products and/or Services.
WHAT PERSONAL DATA CAN I ACCESS?
Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:
The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at [email protected].
If you are a parent or guardian of a member of our Services who is under 13, you may contact us at any time to ask that (a) we stop collecting Personal Data from such Member and (b) we delete any Personal Data already collected from such member. Please contact us at [email protected] to request deletion of the account of an underage member. Be advised that we may ask for additional verification and documentation to confirm your identity and authorization to make this request.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [email protected].
WHAT CHOICES DO I HAVE?
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.
You may be able to add, update, or delete the information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. We may use any aggregated data derived from your Personal Data after you update or delete it, but not in a manner that would identify you personally.
WHAT IF I HAVE QUESTIONS ABOUT THIS POLICY?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to [email protected], and we will try to resolve your concerns.