We at Beta Acid know that you value your privacy. This Privacy Policy explains how we treat information collected through betaacid.co and other websites and online channels we own or operate (collectively, our “Site”), Beta Acid services developing software, applications, or other technology solutions on behalf of a Beta Acid client (our “Solutions”), your communications with Beta Acid in any manner, and other products or services we may offer (collectively with our Solutions and Site, the “Services”). You consent to our privacy practices when you use our Services. If you do not agree with this Privacy Policy, do not use the Services.

Long story short, here is a summary of our privacy practices:

• In most cases, we collect Personal Information when you give it to us.
• You can unsubscribe from Beta Acid emails anytime.
• We never sell your Personal Information or share it with third parties so they can advertise to you.
• We only work with service providers and affiliates that meet or exceed our own privacy standards.
• We welcome your questions about our privacy practices and your requests to exercise your privacy rights.
• This Privacy Policy is governed by our Terms of Use.

We encourage you to read this Privacy Policy carefully to understand how we collect and use your information. If you have questions about this Privacy Policy, please contact us at hi@betaacid.co.

1. What is Personal Information?

When we say, “Personal Information,” we mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or household, such as:

a. Identifiers (e.g., name, email, telephone number, address, username);

b. Sensitive Personal Information (e.g., precise geolocation; race/ethnic origin; religious beliefs; contents of messages when we are not the recipient);

c. Legally protected information (e.g., race, citizenship, marital status, sex);

d. Employment-related information (e.g., current or past employment);

e. Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);

f. Biometrics (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, or olfactory information;

g. Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes;

h. Commercial information (e.g., products/services purchased, obtained, or considered); and

i. Internet or other similar activity (e.g., browsing history; content interactions).

Information that is not protected as Personal Information includes publicly available information; aggregated information (meaning data summaries or reports with the Personal Information removed); or de-identified information that cannot be easily linked back to the individual.

2. How Does Beta Acid Collect and Use Personal Information?

Beta Acid collects Personal Information when you give it to us, from your interactions with the Site, or, in some cases, as a service provider or processor to a client using a Solution we developed on the client’s behalf. We only collect, use, retain, and disclose Personal Information as is adequate and relevant to the specific, express purposes described below or as reasonably necessary and proportionate to achieve our purposes. We may also process Personal Information for other purposes that we disclose to you or as compatible with the context of how we collected your Personal Information.

In the preceding 12 months, Beta Acid has collected Personal Information in the categories of identifiers and internet or similar activity, and, in some limited cases, additional categories of Personal Information when disclosed to Beta Acid by our clients in our role as the client’s service provider or processor. We collect this information from sources and for purposes described below:

a. Your communications with Beta Acid. If you email Beta Acid or contact us through our Site or other means, we will collect identifiers like your name, email, and any information you include in your message to us. If you sign up for our Pourwall, we will also collect the name of your company and the currency in which you do business. We collect this information with your consent, and we use it for the purposes stated at the time of collection and to communicate with you according to your preferences.

b. Solutions Beta Acid develops, as a service provider to our client. Beta Acid develops front-end functionality of Solutions that meet our client’s specifications. These Solutions may collect the user’s identifiers like name, email address, or delivery address, as well as other categories of Personal Information as required by the client. In rare cases, Beta Acid may have access to additional categories of Personal Information as instructed by our client. We collect this information in our role as a service provider to the client, and we use it solely to operate the Solution on the client’s behalf according to the client’s privacy policy. Upon delivery of the Solution, Beta Acid securely transfers operation and control of all Solution data to the client. Please note that Solutions that collect payment information use a PCI-DSS payment processor and Beta Acid never interacts with the payment information. Similarly, health data and similarly sensitive Personal Information is collected and processed using client-provided technology. Beta Acid does not process health data.

c. Solutions hosted by Beta Acid, as a service provider to our client. If a client asks Beta Acid to host the client’s Solution on our systems, Beta Acid will receive and host any categories of Personal Information collected via that Solution. In these cases, Beta Acid collects and processes the Personal Information as a service provider to the client and according to the client’s instructions under a contractual agreement that requires us to maintain the privacy and security of the Personal Information. All such processing is conducted as part of the client’s privacy practices, not ours.

d. Automatically from your Site visit, with a legitimate interest. Beta Acid uses cookies on the Site to collect technical data, including some Personal Information, for analytics purposes. These technologies allow us to analyze user trends, remember a user from one session to the next, and enable certain features to function. Beta Acid uses Google Analytics to analyze your use of our Site and identify technical issues on the Site. If you do not want us to collect or use your Personal Information in this manner, you can adjust your device settings or install a third-party plugin to prevent cookies from interacting with your device or collecting your Personal Information.

e. Other Uses. In addition to the specific uses described above, Beta Acid might also use your Personal Information to (i) monitor your compliance with any of your agreements with us; (ii) protect your privacy and enforce this Privacy Policy; (iii) if we believe it is necessary, to identify, contact, or bring legal action against persons or entities who may be causing injury to you, to us, or to others; (iv) comply with a law, regulation, legal process, or court order; or (v) fulfill any other purpose to which you consent. We will update this Privacy Policy or otherwise notify you before we collect additional categories of Personal Information or use your Personal Information for purposes that are incompatible with the purpose stated at the time of collection.

3. Children’s Privacy

Our Services are designed for adults, not children. If we discover that a child under 18 has provided us with Personal Information, we will delete their information from our systems. If you believe Beta Acid may have any information collected online from a child under 18, or if you become aware of any unauthorized submission of information to Beta Acid, please contact us at hi@betaacid.co.

If a client uses a Solution developed by Beta Acid to collect Personal Information from children online, the client does so under the client’s own privacy practices, not ours. Please direct any questions or concerns about a client’s privacy practices to the client using that Solution.

4. Client’s Privacy Practices

Our clients may use their Solutions to collect Personal Information about their own customers or end users. Beta Acid has no control over the type or scope of Personal Information collected, used or stored by our clients (“Client Data”). Client Data belongs to the client and is collected, processed, stored, shared, and disclosed as part of the client’s privacy practices, not ours. Beta Acid may process Personal Information contained in Client Data as a service provider to the client. However, Beta Acid does not control the client’s privacy practices has no direct relationship with the client’s customers or end users.

5. Retention

We retain the Personal Information we collect about you for the minimum period necessary to achieve our business purposes. When we no longer have a business need for your Personal Information, we will either delete, de-identify or anonymize it whenever feasible. Where deletion is not feasible (such as data in our backup archives) we will securely store the Personal Information and keep it isolated from further processing until it can be permanently deleted.

6. Disclosure

a. For a Business Purpose. Beta Acid discloses Personal Information to certain third parties to achieve our business purposes. In the preceding 12 months, we have disclosed Personal Information from all categories of collection to one or more of the following recipients:

• Service Providers. Beta Acid may disclose Personal Information to its service providers to offer our services to clients and Site visitors. We use a variety of service providers such as data hosting and storage providers, analytics services, and email services. The type of information that we disclose to a service provider will depend on the service that they provide to us. Our service providers are subject to contractual agreements that protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.
• Cookie data recipients, subject to their respective privacy policies.
• Law enforcement or other government agencies, as permitted or required by law.
• Other third parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.

b. Client Access to Data Collected Via Solution. When Beta Acid develops a Solution for a client, the client owns that Solution and all data collected via the Solution. If Beta Acid operates a Solution on behalf of a client, the client will have full access to any Personal Information collected or processed using that Solution.

c. Aggregated and Deidentified Information. We reserve the right to disclose aggregated, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research, or other purposes, without restriction.

7. Your Privacy Rights and Controls

a. Direct Controls. You can directly control much of the Personal Information we collect and hold about you using the methods described below:

• Beta Acid Emails. If you opt-in to receive emails from Beta Acid, we may send you informational or marketing emails about our services and other news. You can unsubscribe from future emails by clicking the “Unsubscribe” link found in any of our emails, or by sending a request to hi@betaacid.co to be removed from our mailing list.
• Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. If this changes in the future, we will update this Privacy Policy.

b. Your Privacy Rights. This section provides the various required notices under the EU General Data Protection Regulations (“GDPR”), Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), and U.S. states like California, Colorado, Connecticut, Iowa, Nevada, Utah, Virginia, and other states require companies to inform consumers about their privacy rights and provide a method to exercise those rights, as well as required notices to Nevada Residents regarding “sale” of personal data. Beta Acid is committed to complying with applicable privacy laws to the extent those laws apply to our company. Depending on where you live and how these laws apply to Beta Acid, you may have the option to exercise some or all of the following rights over your Personal Information:

• Right to know how we collect and process your Personal Information. We have set the required notices in this Privacy Policy. We may provide you with additional notices about other ways we process your Personal Information, such as by sending you a notice via email or by other means of communication.
• Right to expect us to collect, use or disclose Personal Information responsibly and not for any purpose not given at notice. We set your expectations in this Privacy Policy, and we collect legally required consent at various stages of our interactions with you. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as required by law. You may withdraw your consent at any time with reasonable notice by contacting hi@betaacid.co.
• Right to access your Personal Information. You can request to access your Personal Information. Upon request, we will provide you with a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example in order to protect the rights of other individuals. If you are a resident of the State of California, your request is limited to specific pieces of Personal Information we have collected about you over the past 12 months, and we only have to respond to two such requests within a 12-month period.
• Right to accuracy, and the right to correct your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (e.g., change of address), please inform us and we will update our records.
• Right to data portability. In some cases, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.
• Right to deletion or erasure (a.k.a. the “right to be forgotten”). Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.
• No selling or sharing Personal Information. Beta Acid does not sell your Personal Information or share your Personal Information with third parties for cross-contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Policy and provide you with a method to opt-out.
• Limited use and disclosure of sensitive Personal Information. Beta Acid does not seek to collect sensitive Personal Information and in no case do we use or disclose sensitive Personal Information for the purpose of inferring characteristics about any consumer. If this ever changes in the future, we will update this Privacy Policy and provide you with methods to limit use and disclosure of sensitive Personal Information.
• Right to disclosure of certain information about our collection and use of your Personal Information over the past 12 months. If you are a resident of the State of California, you may request that we disclose (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting or selling that Personal Information; and (iv) the categories of third parties with whom we disclose that Personal Information. Additionally, if a business sells or shares Personal Information, the consumer may request two separate lists stating (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Beta Acid is only required to respond to two disclosure requests within a 12-month period.
• Right to restrict processing of your Personal Information. You may have the right to request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object. Your right to restrict processing may be limited to Personal Information that is sensitive in nature, or that is sold or shared for certain purposes.
• Right to object to certain processing of your Personal Information. You may have the right to request, under certain circumstances and where we are required to do so by law, that we will limit our processing of your Personal Information as you request.
• Health Data. Beta Acid does not collect any health data, and we ask that you do not submit any health data to us. However, certain of our clients may collect health data through their Solution. Some laws entitle consumers to certain details about health data collected about them, including confirmation of whether the entity collects, shares, or sells the consumer’s health data and access that data (including a list of all third parties and affiliates with whom the entity has shared or sold the health data and a method to contact those third parties), a method to withdraw consent related to use of health data, and the right to have their health data be deleted. Please contact the client to exercise your rights related to your health data.
• Right to opt-out of profiling or not be subject to Automated Decision-Making (“ADM”). Beta Acid does not use ADM as part of the Site, nor any form of automated processing of Personal Information to evaluate, analyze, or predict your performance, preferences, choices, or behavior. If this changes in the future, we will update this Privacy Policy and provide you with an option to exercise your privacy rights related to Personal Information processed using ADM or other profiling, as applicable.
• Right to disclosure of marketing information. If you are a resident of the State of California, note that California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California Consumers to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.
• Right to nondiscrimination. We will not discriminate against you for exercising any of your privacy rights. If you are a resident of the State of California, we will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights, or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised your statutory right unless permitted by law.

c. Privacy Requests. You can exercise your privacy rights as they apply to you, ask questions, or lodge a complaint by sending an email to hi@betaacid.co, subject to any exceptions and limitations that may apply. If you have questions or concerns related to a Solution we developed, please contact the client that owns that Solution. Upon receipt of your request, Beta Acid will verify your request, including the scope of your privacy request under applicable laws, and respond to your request within the period required by law. If we need more time to fulfill your request, we will notify you in writing of the reason and extension period. If we determine that we process your Personal Information as a processor or service provider to a third party, we will relay your request to the third party for fulfillment. We will deliver our written response by mail or electronically, at your option. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

8. Cross-Border Data Transfers

Beta Acid is owned and operated in the United States. If you access our Site from outside of the U.S., please be aware that the Personal Information we collect about you may be transferred to, processed, stored, and used in the U.S. or other jurisdictions. Privacy laws in the U.S. and other jurisdictions may be different or offer less protections from those of your country of residence. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this section.

Any cross-border transfer of data related to development or use of a Solution Beta Acid develops for a client is at the client’s option and subject to the client’s privacy practices.

9. Data Security

We implement technical, organizational, and physical measures to help protect your information from unauthorized access, processing, or disclosure. We maintain internal policies to govern the collection, processing, access, and handling of data. We use technical safeguards to protect information online and stored on our systems. Please note, however, that no transmission of data over the internet is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes.

10. THIRD-PARTY LINKS AND SOCIAL MEDIA

This Privacy Policy applies only to information collected by Beta Acid. This Privacy Policy does not apply to any third-party websites, applications, or other platforms, such as the Solutions we develop for our clients. Any information collected through those third-party platforms is subject to the privacy practices of the client who owns that Solution, even if Beta Acid provides support in the operations of a Solution for a period. Beta Acid is not responsible for the information practices of third-party websites or platforms. If we provide links to third-party websites, it is your convenience, and we have no responsibility for the privacy practices of that third party. If you access the Site from a social media platform, we may receive Personal Information about you as governed by the terms of use and privacy policy of that platform. We may retain this Personal Information with the information we collect from you by other means.