Last Updated 08/06/2019
2. Changes to this Policy
If we make a material change to this Policy, we will provide you with notice on our Services or to the email address we have on file. By continuing to use the Services after those changes become effective, you agree to be bound by the revised Policy. In addition, we may provide you with additional “just in time” disclosures about our data collection, usage, or sharing practices when you interact with specific parts of our Services.
3. Information We Collect
(a) Information you provide to us
We collect information that may include personal information. Personal information is any information that may reasonably be used to identify you (such as your name, address, and email address), and does not include aggregated or anonymized information.
We collect the information you voluntarily choose to provide to us. Generally, such information will consist of information you enter on any of the forms or logins found on our site. For example, we may collect personal information when you create an account, fill out a form on the Site (e.g., to request product information, register for the BHS Sales Academy, etc.), when you sign up to receive a newsletter, and when you ask a question through our “Contact Us” form. Such information may include the following:
- Personal information such as your name, company, job title, address, phone number, e-mail address, username and password when you create an account or request information about a product or service from us.
- Your preferences and interests, information obtained through customer surveys and/or offers, or other information that you provide us through customer service inquiries.
- Financial information (such as credit card numbers) in connection with a transaction or purchase from our eStore.
(b) Automatic Information
We also automatically collect information when you use our Services (“automatic information”). This includes information we receive from devices when you access our Services, web-behavior information via cookies and other similar tracking technologies when you use or access our Services, and technical information automatically collected by our web server (which may be hosted by a third party), such as the identity of your internet service provider and the type of browser that you use. Each time you visit the Site, our web server automatically recognizes (where possible) and collects this information.
When you use our Services, we may automatically collect the following information about you:
- Device Information: We may collect information about the device you use to access or use our Services. For example, we may collect information such as your device ID or unique identifier, device type, and browser type and version.
- Computer and Connection Information: We may collect information such as statistics on page views, traffic to and from the Services, referral URL, your IP address, your browsing history, and standard web log information.
- Activity Data: While accessing or using our Services, we may collect details regarding your activity on the Site (e.g., browser type and language, performance and usage data) and web-behavior information collected through tracking technology such as cookies.
An Internet Protocol (IP) address is a number assigned to your computer when you connect to the Internet. As part of the protocol of the Internet, web servers can identify your computer by its IP address. In addition, web servers may be able to identify the type of browser you are using or even the type of computer. This information does not identify you personally.
We collect IP addresses for the purposes of system administration and to assess the traffic to our Site. We aggregate this data with data on the pages visited by other users to track overall visitor traffic patterns. We use this information to improve our Site by making it more responsive to the needs and preferences of our users. We do not combine, associate or link IP addresses to your personally identifiable information.
4. Cookies and Other Technologies
Our Site uses “cookies” and other similar tracking technologies including web beacons and pixel tags. Cookies are pieces of information placed on an individual’s computer hard drive that enable the individual to more easily communicate and interact with our Site. Cookie help us recognize you when you use our Services, and allows us to track your click path through our Site.
5. Why We Collect Your Information
We use information, including personal information that we collect about you or that you provide to us through the Services, in the following ways:
(a) To Provide and Maintain Our Products and Services. We may use the information described above in Section 3 to provide, analyze, and improve our Services. For example, we process your personal information to open your account, enable purchases, process payments, communicate with you, and implement your requests (e.g., requests for product information, newsletter sign-ups, and registering for the BHS Sales Academy).
(b) To Provide You with Service-Related Communications. We will send you administrative or account-related information to you to keep you updated about your account and the Services. Such communications may include information about policy updates, confirmations of your account actions or transactions, security updates or tips, or other relevant transaction-related information. We process your contact information to send you such communications. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services.
(c) To Customize Our Services. We may use your information to customize our Services according to your interests, or to tailor our services to your preferences.
(d) To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us with questions, concerns, feedback, and other issues.
(e) To Enforce Compliance with Our Terms, Agreements or Policies. When you access or use our Services, you are bound to our Terms and Conditions and policies, including this Policy. To ensure you comply with our terms, agreements or policies, we process your personal information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services.
(e) To Ensure the Security of the Services. We care about keeping you secure and safe while using our Service. Keeping you safe requires us to process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.
(f) To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws, or as necessary to manage risk as required under applicable law.
(g) To Conduct Research and Development. We may use your information, such as usage data, to conduct analytics and improve our products and services.
(h) To Engage in Marketing Activities. We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided. From time to time, we may also use your information to contact you for market research purposes. You may opt out of marketing emails or other marketing contact by emailing us at [email protected] or by following the unsubscribe instructions in every email.
(i) To Display Advertising. We may use your information to display advertising through third party service providers.
6. Information We Share
BHS does not share, sell, rent, or trade your personal information without your prior consent, and does not share, sell, rent, or trade your personal information to any third party for promotional purposes. This does not include trusted third parties who assist us in operating this Site, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
We take care to allow your personal information to be accessed only by those who really need access to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. We want you to understand when and with whom we may share the information we collect. We may share information that we collect through the Services as follows:
(a) Within Our Corporate Organization. BHS may share your personal information within its corporate organization to provide you with the Services and take actions based on your request.
(c) Service Providers and Agents. BHS employs or engages other companies and individuals to perform business functions on behalf of BHS. These persons may be provided with personal information as required to perform their functions, but are prohibited by contract from using the information for other purposes, except as permitted by law or upon your consent. Our contracts with such persons are at least as protective as this Policy. These persons engage in a variety of functions which include, but are not limited to, analyzing data, providing marketing and technical assistance, processing payments, and providing customer services.
(d) Third Party Business Partners. We may share your name, address, email address, credit card information, and other information with third party business partners (such as our payment processor) to process payment for purchase transactions, deliver marketing communications, and perform other activities that help us provide our Services to you. We will only share such information subject to terms that are at least as protective as this Policy.
(e) Legal Requirements. BHS may disclose your personal information in the good faith belief that such action is necessary to:
– To comply with a legal obligation
– To respond to a valid law enforcement request or other public authority request (such as a court or government agency)
– To protect and defend the rights or property of BHS
– To prevent or investigate possible wrongdoing in connection with the Service
– To protect the personal safety of users of the Service or the public
– To prevent or protect against legal liability
(f) To Protect You, Us, or Others. We may share your personal information if we believe, in good faith, that such disclosure would protect your interests or rights, or the interests or rights of others, including BHS and its personnel.
7. Third Party Links
Occasionally, we may provide links to other websites owned or operated by third parties as a convenience to our visitors. We have no control over linked sites or the privacy practices of these third parties, and make no representations about any content or material available at these locations. We are not responsible for the content of those sites.
BHS takes precautions to safeguard your personal information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. Nevertheless, we request that you not disclose private or confidential information to us via the website.
We implement a variety of security measures, both technical and physical, to maintain the safety of your personal information when you place an order or access your personal information. We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted and is only accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. We also restrict access to personal information based on job function, and implement double authentication procedures for access to networks and data systems. We also encrypt our email communications and any payment and financial data that is transmitted online.
9. Retention of Your Personal Information
As permitted by applicable law, you may delete your account by sending a request to delete your personal information to [email protected] However, your deletion request may be limited as necessary to comply with our legal obligations, resolve disputes, or enforce our agreements, or to protect the rights and interest of others. We will try to fulfill your request without undue delay.
While retention requirements can vary by jurisdiction, we generally apply the retention periods noted below. Please contact us if you have any questions about our retention periods.
- Marketing. We store your marketing contact information for as long as you are still subscribed. When you unsubscribe from marketing communications, we will add your contact information to our suppression list to ensure we respect your unsubscribe request.
- Activity Data. We may store activity data indefinitely after the closure your account for the establishment or defense of legal claims, audit and crime prevention purposes.
10. International Transfers
If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland at the time your information is collected, we transfer your information so as to enter into and perform a contract to provide you with services, and such transfers are subject to appropriate safeguards as permitted under the applicable data protection laws. When we transfer your personal information, we require contractual provisions for transferring Personal Information in place with the third parties to which your information is transferred that are consistent with the GDPR.
Our Site is not designed to attract children under the age of 18. BHS does not knowingly solicit or collect personally identifiable information online from children under the age of 18. If BHS learns that a child under the age of 18 has submitted personally identifiable information online, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personally identifiable information we have collected from children under 18, please contact us at [email protected]
12. Right to Opt-Out
You may choose to have your name taken off of our email list, or review and/or update the registration information that you have provided to us by one of the following methods. If you disagree with the manner in which we intend to use the personal information you provide to us, you may opt-out of these uses by providing us clear instructions to the postal or email addresses listed below. BHS Global, Ltd., c/o Marketing Department, P.O. Box 1242, St. Louis, MO 63132 or email us at [email protected]
13. “Do Not Track” Signals
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform apps that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
14. Your California Privacy Rights
If you are a California resident you may request a notice from us describing what categories of personal information (if any) we have shared with third parties, including our corporate affiliates, for direct marketing purposes during the preceding calendar year. You may request such notice once a year and free of charge. To request a notice, please contact us as provided in the “Contact Us” section of this Policy. In your request, please specify that you want a “California Privacy Rights Notice.” We will respond to you with thirty (30) days or as permitted by law.
15. Information for Customers in Europe
If you are located in the EEA, the United Kingdom, or Switzerland (“Designated Countries”) at the time of data collection, you have certain data protection rights under the General Data Protection Regulation (“GDPR”). We may ask you to identify which country you are located in when you use our Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to users in the Designated Countries.
Our Relationship to You
BHS is a data controller with regard to any personal information collected from individuals accessing or using our Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers or are otherwise acting on our behalf are “data processors” that handle your Personal Information in accordance with our instructions.
We will only contact individuals located in the Designated Countries by electronic means (including email or SMS) as permitted by applicable law, or the individual’s consent. When we rely on legitimate interest, we will only send you information about our services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. You can object to direct marketing at any time and free of charge by contacting us at [email protected]
Legal Basis for Processing Your Personal Information
We describe our legal bases for processing throughout this Policy. Below is a list of the purposes described in our Policy with the corresponding legal basis for processing.
|Purpose for Processing||Legal Basis for Processing|
|5(a) To Provide and Maintain Our Products and Services
5(b) To Provide You with Service Related Communications
5(d) To Provide Customer Support or Respond to You
6(a) Sharing within the Corporate Organization.
6(c) Sharing with Service Providers and Agents
6(d) Sharing with Third Party Business Partners
|Based on our contract with you or to take steps at your request prior to entering into a contract.|
|5(j) To Display Advertising||Based on your consent.|
|5(e) To Enforce Compliance with Our Terms, Agreements or Policies
5(f) To Ensure Security of Our Services
5(g) To Maintain Legal and Regulatory Compliance
6(e) Sharing Due to Legal Requirements
|Based on our legal obligations.|
|5(c) To Customize Our Services
5(h) To Conduct Research and Development.
|Based on our legitimate interests. When we process your personal data for our legitimate business interests we always ensure that we consider and balance any potential impact on you and your rights under data protection laws.|
Your Individual Rights
In certain circumstances, you have the following data protection rights. We may limit your individual rights requests in the following ways: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; (c) to protect our rights and properties; and (d) where the request is frivolous or burdensome. If you would like to exercise your rights under the applicable law, please contact us at [email protected] Please note that we may ask you to verify your identity before responding to such requests.
- Right to Withdraw Your Consent. If we ever asked for your consent to process your personal information, you have the right to withdraw your consent at any time.
- Right of Access. Upon your request, we will provide you with a copy of your personal information in our files without undue delay and free of charge, unless we permitted by law to charge a fee.
- Right to Rectification (or “Correction”). You may request to correct or update any of your personal information in our files.
- Right to Erasure (or the “Right to be Forgotten”). Upon your request, we will erase any of your personal information in our files that is no longer necessary in relation to the purposes for which it was processed, was collected in relation to processing that you previously consented to, but later withdrew such consent, or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
- Right to Restriction. You have the right to restrict our processing of your personal information where one of the following conditions applies:
- You contest the accuracy of your personal information that we processed. If you restrict processing based on this condition, you may experience an interruption of some or all of the services during the period necessary for us to verify the accuracy of your personal information;
- The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;
- We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or
- You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.
- Right to Object. You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent; contract; or legitimate interests.
- Right to Data Portability. If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information and to have us transfer your personal information directly to another “controller,” where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
- Notification to Third Parties. When we fulfill your individual rights requests for correct (or rectification), erasure or restriction of processing, we will notify third parties also handling the relevant personal information unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.
- Automated Individual Decision-Making. In establishing and carrying out a business relationship, we do not use any automated decision making that has any legal or other significant effects on you.
If you believe that we have infringed or violated your privacy rights under applicable law or this Policy, please contact us at [email protected] so that we can work with you to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.
16. Contact Us