Data Policy

This policy describes the information we process to support BEPUPPY and other products and features offered by BEPUPPY (BEPUPPY Products or Products). The BEPUPPY Products include BEPUPPY and any other features, apps, technologies, software, products, or services offered by Marco Martinenghi.

What kinds of information do we collect?

To provide the BEPUPPY Products, we must process information about you. The types of information we collect depend on how you use our Products.

Things you and others do and provide.

  • Information and content you provide. We collect the content, communications and other information you provide when you use our Products, including when you sign up for an account, create or share content, and message or communicate with others. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created.
  • Networks and connections. We collect information about the people, Channels, accounts, hashtags and groups you are connected to and how you interact with them across our Products, such as people you communicate with the most or groups you are part of. We also collect contact information if you choose to upload, sync or import it from a device (such as an address book), which we use for things like helping you and others find people you may know.
  • Your usage. We collect information about how you use our Products, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency and duration of your activities.
  • Information about transactions made on our Products. If you use our Products for purchases or other financial transactions (such as when you make a donation), we collect information about the purchase or transaction.
  • Things others do and information they provide about you. We also receive and analyze content, communications and information that other people provide when they use our Products. This can include information about you, such as when others share or comment on a photo of you, send a message to you, or upload, sync or import your contact information.

Device Information

As described below, we collect information from and about the computers, phones and other web-connected devices you use that integrate with our Products, and we combine this information across different devices you use. For example, we use information collected about your use of our Products on your phone to better personalize the content (including ads) or features you see when you use our Products on another device, such as your laptop or tablet, or to measure whether you took an action in response to an ad we showed you on your phone on a different device. Information we obtain from these devices includes:

  • Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.
  • Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
  • Identifiers: unique identifiers, device IDs, and other identifiers.
  • Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.
  • Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
  • Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network.
  • Cookie data: data from cookies stored on your device, including cookie IDs and settings. Learn more about how we use cookies in the BEPUPPY Cookies Policy.

Information from partners.

We receive information about you and your activities on and off BEPUPPY from third-party partners, such as information from a partner when we jointly offer services or from an advertiser about your experiences or interactions with them. Partners receive your data when you visit or use their services or through third parties they work with. We require each of these partners to have lawful rights to collect, use and share your data before providing any data to us.

How do we use this information?

We use the information we have (subject to choices you make) as described below and to provide and support the BEPUPPY Products.

Provide, personalize and improve our Products.

We use the information we have to deliver our Products, and make suggestions for you (such as groups you may be interested in or topics you may want to follow) on and off our Products. To create personalized Products that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others; how you use and interact with our Products; and the people, places, or things you're connected to and interested in on and off our Products.

  • Information across BEPUPPY Products and devices: We connect information about your activities on different BEPUPPY Products and devices to provide a more tailored and consistent experience on all BEPUPPY Products you use, wherever you use them.
  • Location-related information: We use location-related information-such as your current location, where you live, the places you like to go, and the businesses and people you're near-to provide, personalize and improve our Products, including ads, for you and others. Location-related information can be based on things like precise device location (if you've allowed us to collect it), IP addresses, and information from your and others' use of BEPUPPY Products.
  • Product research and development: We use the information we have to develop, test and improve our Products, including by conducting surveys and research, and testing and troubleshooting new products and features.
  • Ads and other sponsored content: We use the information we have about you-including information about your interests, actions and connections-to select and personalize ads, offers and other sponsored content that we show you

Provide measurement, analytics, and other business services.

We use the information we have (including your activity off our Products, such as the websites you visit and ads you see) to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps, and services.

Promote safety, integrity and security.

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off of BEPUPPY Products.

Communicate with you.

We use the information we have to send you marketing communications, communicate with you about our Products, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

How is this information shared?

Your information is shared with others in the following ways:


Sharing on BEPUPPY Products


People and accounts you share and communicate with

When you share and communicate using our Products, you choose the audience for what you share. Your network can also see actions you have taken on our Products, including engagement with ads and sponsored content. Public information can be seen by anyone, on or off our Products, including if they don't have an account. This includes any information you share with a public audience; information in your public profile on BEPUPPY; and content you share on a BEPUPPY Channel or any other public forum. You, other people using BEPUPPY, and we can provide access to or send public information to anyone on or off our Products, including in other BEPUPPY Company Products, in search results, or through tools and APIs. Public information can also be seen, accessed, reshared or downloaded through third-party services such as search engines, APIs, and by apps, websites and other services that integrate with our Products.

Content others share or reshare about you

You should consider who you choose to share with, because people who can see your activity on our Products can choose to share it with others on and off our Products, including people and businesses outside the audience you shared with. For example, when you share a post or send a message to specific friends or accounts, they can download, screenshot, or reshare that content to others across or off our Products. Also, when you comment on someone else's post or react to their content, your comment or reaction is visible to anyone who can see the other person's content, and that person can change the audience later. People can also use our Products to create and share content about you with the audience they choose. For example, people can share a photo of you, mention or tag you at a location in a post, or share information about you in their posts or messages. If you are uncomfortable with what others have shared about you on our Products, you can report the content.

Information about your active status or presence on our Products.

People in your networks can see signals telling them whether you are active on our Products, including whether you are currently active on BEPUPPY, or when you last used our Products.

Apps, websites, and third-party integrations on or using our Products.

When you choose to use third-party apps, websites, or other services that use, or are integrated with, our Products, they can receive information about what you post or share. Also, when you download or use such third-party services, they can access your public profile on BEPUPPY, and any information that you share with them. Information collected by these third-party services is subject to their own terms and policies, not this one.

New owner.

If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.


Sharing with Third-Party Partners


We work with third-party partners who help us provide and improve our Products. We don't sell any of your information to anyone. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties we share information with:

Advertisers.

We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. We also confirm which BEPUPPY ads led you to make a purchase or take an action with an advertiser.

Partners offering goods and services in our Products.

When you subscribe to receive premium content, the content creator can receive your public information and other information you share with them, as well as the information needed to complete the transaction.

Vendors and service providers.

We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Products are used, providing customer service, facilitating payments or conducting surveys.

Law enforcement or legal requests.

We share information with law enforcement or in response to legal requests in the circumstances outlined below.

What is our legal basis for processing data?

We collect, use and share the data that we have in the ways described above:

  • as necessary to fulfill our BEPUPPY Terms of Service;
  • consistent with your consent;
  • as necessary to comply with our legal obligations;
  • to protect your vital interests, or those of others;
  • as necessary in the public interest; and
  • as necessary for our (or others') legitimate interests, including our interests in providing an innovative, personalized, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.

How can you exercise your rights provided under the GDPR?

Under the General Data Protection Regulation, you have the right to access, rectify, port and erase your data. You also have the right to object to and restrict certain processing of your data. This includes:

  • the right to object to our processing of your data for direct marketing, which you can exercise by using the "unsubscribe" link in such marketing communications; and
  • the right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can exercise this right on BEPUPPY.

Data retention, account deactivation and deletion

We store data until it is no longer necessary to provide our services and BEPUPPY Products, or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. When you delete your account, we delete things you have posted, such as your photos and status updates, and you won't be able to recover that information later. Information that others have shared about you isn't part of your account and won't be deleted. To delete your account at any time, please visit our contact page.

How do we respond to legal requests or prevent harm?

We access, preserve and share your information with regulators, law enforcement or others:

  • In response to a legal request, if we have a good-faith belief that the law requires us to do so. We can also respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
  • When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorized use of the Products, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Products.

Information we receive about you (including financial transaction data related to purchases made with BEPUPPY) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.

How do we operate and transfer data as part of our global services?

We share information globally, both internally within the BEPUPPY Companies and externally with our partners and with those you connect and share with around the world in accordance with this policy. Information controlled by Marco Martinenghi will be transferred or transmitted to, or stored and processed in, Switzerland or other countries outside of where you live for the purposes as described in this policy. These data transfers are necessary to globally operate and provide our Products to you. We utilize standard contractual clauses approved by the European Commission and rely on the European Commission's adequacy decisions about certain countries, as applicable, for data transfers from the EEA to Switzerland and other countries.

How will we notify you of changes to this policy?

We'll notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our Products.

How to contact BEPUPPY with questions

The data controller responsible for your information is Marco Martinenghi.

Date of Last Revision: June 4, 2018