Privacy Policy

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Effective Date:  April, 2021

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Builtfirst Technologies, Inc. (“BF”, “we” or “us”) provides its website and certain platforms, services, functions and features (each of the foregoing referred to individually, and all of the foregoing referred to collectively, as the “Site”) to each user of the Site (“User”, “you” or “your”).  This Privacy Policy explains the types of information we may collect via the Site or other sources, how we use and share such information and purposes for doing so.  It also describes how we protect your Personal Information (see definition below) and how you may exercise control over your own Personal Information.  To the extent you access or use the Site in any manner, this Privacy Policy will apply to you, so please read it carefully.  If you do not agree to any term or condition provided herein, please do not access or use the Site. 

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1. Information BF Collects & How it is Collected

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We collect both Non-Personal Information and Personal Information.

Non-Personal Information: “Non-Personal Information” refers to information which does not identify a User or any other natural person.  We collect the following types of Non-Personal Information in the manner described below: 

• Site usage data, such as web pages visited, visit date and time, amount of time spent on particular pages and other information about how you navigate on or use our Site.  We collect site usage data automatically as you use the Site.
• Internet Protocol (IP) addresses that are not used or stored by us to identify any User or User’s device.  We collect IP addresses automatically as you use the Site. 
• Information about organizations or businesses, such as a business’ name, description, services/products offered, logo or website/domain.  We collect this information if a User chooses to upload it to the Site, including if the User chooses to add such information to the User’s profile on the Site.  We also collect this information in connection with our business dealings, partnerships and collaborations with such businesses or organizations.
• Location data that does not include specific addresses or information that may be used to identify any User or individual.  We collect this information (such as country in which a company is headquartered) if a User chooses to add it to a profile on the Site. 

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Personal Information: “Personal Information” refers to information which identifies a User or natural person or which could reasonably be used to identify a User or natural person.  We collect the following types of Personal Information:

• Names.  We collect names when a User provides it to us on the Site (e.g., when setting up an account or profile on the Site or when including it with submission of a question/comment to us).
• Email addresses.  We collect work-related email addresses when a User provides it to us on the Site (e.g., when setting up an account or profile on the Site).  We also collect any email address that is included with submission of a comment/question to us.
• Social media profile information.  We collect social media profile information if a User chooses to share this information in the User’s profile on the Site.
• Account information, such as account credentials and account-related activity (e.g., sign-in counts for an account).  We collect account information in the account set-up process and as Users engage in activities related to their account (such as when they sign into the account). 
• Employment and/or work-related information.  We collect this information, which may include, without limitation, a User’s title or affiliation with a business, when a User provides it (such as when a User includes such information in a profile on the Site).

2. BF’s Uses and Sharing of Information & Purposes of Using and Sharing Information

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Use and Sharing of Non-Personal Information:  We use Non-Personal Information we collect to operate the Site, including to address technical and/or security issues relating to the operation of the Site.  We also use Non-Personal Information to customize and improve the Site and for web analytics purposes (e.g. analyzing trends and Users' preferences in using the Site).  We use third party web analytics tools, such as Google Analytics, to track Site usage and traffic.

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We share the following Non-Personal Information for purposes described below:

• We share all Non-Personal Information described in Section 1 above with our vendors and contractors who assist us in connection with operating the Site.  For example, we share Non-Personal Information with our vendors who host Non-Personal Information on their secure servers.
• Users who we have approved to offer their products or services via our Site (hereinafter, “Providers”) may post Non-Personal Information about their organizations or businesses and details of the offer being made by such organizations or businesses via the Site.  We share this Non-Personal Information in the form of the post on our Site, which is visible to, and shared with, other Users. 
• We share Non-Personal Information about organizations or businesses included in offers made by Providers to assist and provide services to other Users who establish an account with us and who seek to qualify for perks and discounts offered by those Providers via the Site (such other Users are hereinafter referred to as “Founders”).  For example, we may share Non-Personal Information with a Founder in the process of matching the Founder with a Provider that offers perks for which the Founder qualifies.
• We share information about organizations with which we partner or collaborate, such as the organization’s name and logo, on our website with such organization’s consent.

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Use and Sharing of Personal Information: We use the following Personal Information for purposes described below:

• We use names and email addresses of Users and other individuals to respond to questions and comments submitted to us through the Site, including through the “Contact Us” page of our website
• We use names and email addresses to verify the identity of Users or identify individuals who use the Site inappropriately or in violation of our terms of use or this Privacy Policy.  We use such information to respond to such incidents as necessary under the circumstances.
• We use account and profile information of Users to assist Users in managing such information and responding to requests and inquiries related to such accounts and profiles.
• We use any of the Personal Information described in Section 1 above to comply with applicable law, regulation, legal process, subpoena or governmental request, or to protect the rights or property of BF or its Users, as needed.
• We use any of the Personal Information described in Section 1 above to respond to claims that content posted or made available on the Site violates rights of third parties.
• We use any of the Personal Information described in Section 1 above in connection with any change in control of BF, including by means of merger, acquisition or purchase of all or substantially all of BF’s assets.

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We share the following Personal Information for purposes described below:

• We share names, email addresses, employment and/or work-related information and social media profile information of Providers or Users associated with Providers in the form of a posting on our Site, which is visible to Founders.  We share this information as part of our Site services.
• We share email addresses and employment and/or work-related information of Founders (or Users associated with Founders) with Providers.  We share this information as a part of our Site services.
• We share any of the Personal Information described in Section 1 above with our vendors and contractors who assist us with operating the Site.  For example, we share Personal Information with our vendors who host Personal Information on their secure servers.
• We share any of the Personal Information described in Section 1 above as required to comply with applicable law, regulation, legal process, subpoena or governmental request, or to protect the rights or property of BF or its Users, as needed.
• We share any of the Personal Information described in Section 1 above to respond to claims that content posted or made available on the Site violates rights of third parties.
• We share any of the Personal Information described in Section 1 above in connection with any change in control of BF, including by means of merger, acquisition or purchase of all or substantially all of BF’s assets.
• We share any of the Personal Information described in Section 1 above as needed to enforce our Site terms of use or this Privacy Policy.

3. Retention of Personal Information

Unless you request that we delete your Personal Information (please see Section 10 below), we may retain your Personal Information for as long as reasonably required for fulfilling the purposes of using and disclosing such Personal Information described above, in each case as permitted under applicable laws and regulations.

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4. Third Party Software and Services

In some cases, we use third party software, applications, platforms or services to collect, store, transmit or otherwise handle the Non-Personal Information and Personal Information described above.  We make commercially reasonable efforts to engage only with third parties that comply with applicable law and implement reasonable information privacy and security measures; however, please be aware we do not control such third parties.  

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5. Security

We use commercially reasonable administrative, technical, physical and organizational security measures to maintain the security and integrity of our Site and Non-Personal Information and Personal Information we collect or maintain as a part of our Site.  We implement measures to protect against loss, misuse, or improper access through generally accepted industry standard technologies and internal procedures.  For example, User accounts on our Site are password-protected and we enable encryption of passwords.  Please note that there are inherent risks in transmission of information over the Internet, and we cannot guarantee that unauthorized access or use of information will never occur.

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6. Tracking Technologies

As noted above, we use Google Analytics to track Site usage and traffic.  We may also use other tracking technologies such as cookies, web beacons and/or similar tracking mechanisms on our Site ("Tracking Technologies"), in accordance with applicable laws.  Such Tracking Technologies are stored on your computer or other device used to access our Site.  Tracking Technologies may enable activation of certain features and make your use of our Site simpler and more convenient.  You may disable Tracking Technologies by adjusting your browser settings, but if you do so, certain features on our Site may not function properly.

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7. Links to Third Party Content

Our Site may include links to third party content, including without limitation, links to third party websites posted by Users or provided by us on our Site.  We do not endorse or recommend such third party content and we are not responsible for the privacy practices of the operators or publishers of such content.  Please be aware that when you access links to a third party’s content via our Site, you are bound by the privacy policies and practices of that third party. We urge you to be aware of and read the privacy policies governing your use of any third party content.

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8. Children Under 13

Our Site is not directed to or intended to be used by children under the age of 13 and we do not knowingly collect any Personal Information from children under 13.  If you become aware that we have collected Personal Information from any child under the age 13, we ask that you contact us (see our contact information at the end of this Privacy Policy) and we will seek to delete such Personal Information as soon as possible.

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9. International Data Transfer

In the course of providing our Site services to you, we may transfer information collected about you across borders from the country in which you are located to other countries around the world, as permitted by applicable laws.  Please note that we may transfer such information to a country that does not have the same privacy or data protection laws as your country.  Accordingly, with respect to an international data transfer, your Personal Information may be subject to different protections depending on the laws and regulations of the country to which your Personal Information is transferred.  In all cases, we will seek to apply reasonable safeguards for the protection of any Personal Information transferred internationally.

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10. Deletion or Modification of Personal Information

If you wish to delete or modify your Personal Information that we have collected, please email us at aaron@builtfirst.com, and we will make reasonable efforts to delete or modify your Personal Information pursuant to your request.  In your request, please include specific details about which Personal Information you would like us to delete or modify.  

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11. Individuals in the European Union and United Kingdom

In addition to all of the foregoing terms of this Privacy Policy, the following terms apply to individuals in the European Union (EU) and United Kingdom (UK):

BF is a “controller” (entity that determines the purposes and means of processing your Personal Information) with regard to the Personal Information we collect from you on the Site.  You may contact BF at aaron@builtfirst.com.

When we collect your Personal Information on the Site and use, share and otherwise process it for the purposes described above in this Privacy Policy, our processing of your Personal Information has various legal bases, depending on the particular circumstances, which may include (a) our legitimate interests in operating our Site and providing you with Site services; (b) for compliance with a legal obligation to which we are subject; (c) for performance of a contract to which you are subject or to take certain pre-contractual measures at your request; and (d) your consent. 

As a data subject, you have the right to request from BF access to, rectification of, erasure of, portability of and/or restriction of processing of your Personal Information.  You also have the right to object to further processing of your Personal Information. To exercise any of these rights, please contact BF at aaron@builtfirst.com.  We will respond to your request in accordance with applicable law.

In the event we process your Personal Information based on your consent, you may withdraw your consent at any time (provided, however, such withdrawal will not affect the lawfulness of processing of your Personal Information that occurred before BF’s receipt of your withdrawal).  To withdraw consent for processing of your Personal Information, please contact us at aaron@builtfirst.com.

We may transfer Personal Information from the EU and/or UK to the United States.  Please be aware that the European Commission has not determined that the United States provides an adequate legal framework for the protection of Personal Information.  Nonetheless, BF commits to protect Personal Information by applying reasonable safeguards to Personal Information transferred to the United States.

Please note that you are not required to provide BF with your Personal Information; provided, however, if you choose not to provide your Personal Information, this means that you will not be able to receive the Site services and/or products which depend on our processing of your Personal Information as described in this Privacy Policy.

If you have a concern with the handling of your Personal Information, you may lodge a complaint with the applicable data protection authority (also known as “Supervisory Authority”) in the country in which you reside.  For a list of Supervisory Authorities and their contact information, please visit: https://edpb.europa.eu/about-edpb/board/members_en.  If you have a concern, you may also contact BF at aaron@builtfirst.com.

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12. Changes to this Privacy Policy

We may change this Privacy Policy at any time.  In any case where we substantially change the terms of this Privacy Policy, we will post a banner on our website notifying Users and others of the updated Privacy Policy and including a link to the updated Privacy Policy.  Any updated Privacy Policy will include a date indicating when the Privacy Policy was last revised.  

Questions?

If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us at aaron@builtfirst.com and we will attempt to respond as soon as possible.