Privacy Policy

Last Updated: June 14, 2023

Bensussen Deutsch & Associates, Inc. Global Privacy Policy

This privacy statement describes how Bensussen Deutsch & Associates, LLC, doing business as SwagUp, collects, uses, discloses and processes personal information about individuals.

Definitions

• BDA Associate: Person employed by BDA
• Client: Company doing business with BDA
• Customer: Person with at least one interaction with a client-branded program store operated by BDA
• Promotional Shopper: Person with interaction with BDA for promotional item opportunity or order
• Promotional Item Recipient: Person receiving promotional item via campaign

Changes

The company may update this policy and will notify users by revising the date at the top. Material changes receive additional notice.

Exclusions

This policy does not apply to websites BDA operates as a service provider for clients. When processing information on behalf of clients, BDA adheres to client instructions and applicable privacy policies.

Collection of Information

Information You Provide

• Name, email, phone, postal address, job title, billing information, payment details, or other voluntarily provided information
• Payment processing handled by third-party processors

Information Automatically Collected

• Transactional Information: Quotes, orders, transaction details, communications
• Web Activity Information: Login data, pages viewed, links clicked, session times
• Device and Usage Information: Hardware type, operating system, IP address, browser type
• Cookies and Tracking Technologies: Small data files and web beacons used to improve experience, track popularity, and count visits

Information Derived

The company may create inferences about users based on collected data (e.g., product interest based on browsing).

Children's Data

BDA does not knowingly collect information from anyone under 16 or allow such persons to register.

Use of Information

The company uses collected information to:

• Provide and maintain services, debug errors
• Send support and transactional messages
• Communicate about products and services
• Monitor trends, usage, and activities
• Detect and prevent security incidents and fraud
• Comply with legal obligations
• Conduct internal operations
• Create anonymized or aggregated information

The company works with third-party advertising companies using cookies across services and websites to serve targeted ads. Users can limit interest-based advertising through opt-out mechanisms.

Disclosures of Information

Personal information is disclosed to:

• Service providers and vendors delivering services
• Public/other users when customers post reviews or content
• Employer/client when ordering on behalf of employer
• Employer's business partners
• When actions violate agreements, laws, or threaten rights/safety
• During corporate transactions (mergers, sales, acquisitions)
• Between BDA parent companies, affiliates, subsidiaries
• With user consent
• As aggregated or de-identified information
• Vendor platforms for payroll, benefits, hiring
• Third parties partnering on advertising or collecting activity data

Analytics

Web analytics tools use cookies, tags, and technologies to collect information about service usage, including browser type, pages viewed, time on pages, links clicked, and conversion data.

Transfer of Information

BDA is headquartered in the US with operations and vendors globally. Personal information may be transferred to jurisdictions with different data protection levels. Where required by law, adequate protections are provided through consent, adequacy decisions, or Standard Contractual Clauses.

Your Choices

Cookies

Most browsers allow removing or stopping cookie acceptance. Users can manage cookies through browser settings. Disabling cookies may limit website functionality.

Advertising Choices

Users can minimize interest-based advertising by blocking third-party cookies, using browser extensions, or adjusting device settings.

Access, Deletion, Correction, and Other Rights

Subject to limitations and applicable law, individuals may request to:

1. Know categories and specific personal information collected, used, and disclosed
2. Request deletion of personal information
3. Opt out of “sales” or “sharing”
4. Request data transmission to another entity (portability)
5. Correct inaccurate information
6. Limit sensitive information use and disclosure
7. Know about automated decision-making
8. Opt out of automated decision-making
9. Not be discriminated against for exercising rights

Requests can be submitted via email: dpo@bdainc.com.

California-Specific Disclosures (CCPA/CPRA)

Collection categories in the preceding 12 months include: personal identifiers (name, address, email, IP address, account name), commercial information, internet/electronic network activity, and audio/electronic/professional/employment information.

BDA does not sell or share personal information with third parties as defined under CPRA.

California rights include: Know/Access, Delete, Correct, Opt-Out of Sales/Sharing, and Nondiscrimination.

European Disclosures (GDPR/EEA/UK/Switzerland)

Legal basis for processing includes contract performance, legitimate business interests, legal compliance, and user consent (withdrawable).

Data retention:

• Account data retained while active; deleted after two years of inactivity
• Other personal data retained as necessary
• Cookie data retained up to two months upon consent

Additional rights include objecting to processing, withdrawing consent, and requesting restrictions. Submit requests to dpo@bdainc.com.

Contact Information

Data Protection Officer

• Email: dpo@bdainc.com
• Mailing Address: BDA World Headquarters, Attn: Data Privacy Officer, 15525 Woodinville-Redmond RD. NE., Woodinville, WA 98072