At 3r Behavioral Solutions, inc. trust is our #1 value. This 3r Behavioral Solutions Privacy Statement (“Privacy Statement”) describes our privacy practices. Please read this Privacy Statement carefully to learn how we collect, use, share and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding our processing of your Personal Data.
A reference to “3r Behavioral,” “we,” “us” or the “Company” is a reference to 3r Behavioral Solutions, inc.
1. Processing activities covered
This Privacy Statement applies to the processing of Personal Data collected by us when you:
- Visit our websites and applications that display or link to this Privacy Statement;
- Visit our branded social media pages;
- Visiting our offices;
- Receive communications from us, including emails, phone calls, texts or fax;
- Register for our events, webinars or contests; or
Participate in community and open source development.
2. Responsible 3r Behavioral Solutions entity
3r Behavioral Solutions is the controller and a processor of your Personal Data as described in this Privacy Statement unless expressly specified otherwise.
Data controller: We collect and manage the personal data of our client.
Data processor: We store or process data for our clients and manage the technical implementation of the services provided. These clients can provide us with their own customer data which we collect and process. We also use third party data processors. For example, we use Zoho Analytics which processes the data of users to create charts/reports.
This Privacy Statement does not apply to the extent we offer to our customers’ various cloud products and services through which our customers create their own websites and applications running on our platforms, sell or offer their own products and services, send electronic communications to other individuals or collect and analyze Personal Data from individuals.
3. What Personal Data do we collect?
3.1 Personal Data we collect directly from you
The Personal Data that we collect directly from you includes the following:
- If you express an interest in obtaining additional information about our services, request customer support, use our “Contact Us” or similar features, register to use our websites, sign up for an event, webinar or contest, or download certain content, we may require that you provide to us your contact information, such as your name, job title, company name, address, phone number, email address or username and password;
- If you make purchases via our websites or register for an event or webinar, we may require that you provide to us your financial and billing information, such as billing name and address, credit card number or bank account information;
- If you attend an event, we may upon your consent scan your attendee badge, which will provide to us your name, title, company name, address, country, phone number, and email address;
- If you register for an online community that we host, we may ask you to provide a username, photo and/or biographical information, such as your occupation, social media profiles, company name and areas of expertise;
- If you use and interact with our websites, we automatically collect log files and other information about your device and your usage of our websites through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, using services like Google Analytics which may qualify as Personal Data (please see the “What device and usage data we process” section, below); and
- If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival.
- If you create a user from Configurator web-app, we may require that you provide us your contact information, such as your name, company name, phone number, email address, profile image, etc.
If you provide to us or to our service providers any Personal Data relating to other individuals, you represent that you have the authority to do so and permit us to use the Personal Data in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact us by using the information in the “Contacting us” section, below.
4. What device and usage data we process
We use common information-gathering tools, such as log files, cookies, web beacons and similar technologies to automatically collect information that may contain Personal Data from your computer or mobile device as you navigate our websites or interact with emails we have sent to you.
4.1 Notices on behavioral advertising and opt-out
As described above, we or third parties may place or recognize a unique cookie on your browser when you visit our websites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). To learn more about targeted advertising and advertising networks and about your ability to opt-out of collection by certain third parties, please visit the opt-out pages of the Network Advertising Initiative, here, and the Digital Advertising Alliance, here.
To manage the use of targeting or advertising cookies on this website, consult your individual browser settings for cookies. To learn how to manage privacy and storage settings for Flash cookies, click here.
4.2 Opt-Out from the collection of device and usage data
You may opt-out from the collection of device and usage data (see the “What device and usage data we process” section, above) by managing your cookies at the individual browser level. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the websites.
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites. 3r Behavioral Solutions takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
4.3 Log Files
As is true of most websites, we gather certain information automatically via log files. This information may include your IP address (or proxy server), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system, and system configuration information and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our websites and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into our services as part of our security features.
4.4 Cookies, web beacons, and other tracking technologies
We use cookies and similar technologies such as web beacons, tags and JavaScript alone or in conjunction with cookies to compile information about the usage of our websites and interaction with emails from us.
When you visit our websites, we or an authorized third party may place a cookie on your browser, which collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track overall usage, determine your browsing preferences and improve and customize your browsing experience.
We use both session-based and persistent cookies. Session-based cookies exist only during one session and disappear from your computer when you close your browser or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but choosing to disable cookies may limit your use of certain features or functions on our websites and services.
We also use web beacons on our websites and in email communications. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. Such technologies are used to operate and improve our websites and email communications.
The following describes how we use different categories of cookies and similar technologies and your options for managing the data collection settings of these technologies:
| TYPE OF COOKIES | DESCRIPTION | MANAGING SETTINGS |
|---|---|---|
| Required cookies | Required cookies enable you to navigate our websites and use their features, such as accessing secure areas of the websites.If you have chosen to identify yourself to us, we may place on your browser a cookie that allows us to uniquely identify you when you are logged into the websites and to process your online transactions and requests. | Because required cookies are essential to operate the websites, there is no option to opt-out of these cookies. |
| Functional cookies | Functional cookies allow us to remember information you have entered or choices you make (such as your username, language, and region) and provide enhanced, personalized features.Functional cookies may also be used to improve how our websites function and to help us provide you with more relevant communications, including marketing communications. These cookies collect information about how our websites are used, including which pages are viewed most often.
We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications and to track the performance of our advertisements. In particular, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the websites from which visitors have navigated to our websites, and the pages on our websites to which visitors navigate. This information is used by us to improve our websites. 3r Behavioral Solutions may also utilize HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it. |
You can manage the placement of functional cookies on your browser via your individual browser settings. Note that opting out of functional cookies may impact the functionality of our websites and degrade your user experience.To opt-out from data collection by Google Analytics, you can download and install a browser add-on, which is available here.
To learn how to control functional cookies via your individual browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here |
5. Purposes for which we process Personal Data and the legal bases on which we rely
We collect and process your Personal Data for the purposes and on the legal bases identified in the following:
- Providing our websites: We process your Personal Data to perform our contract with you for the use of our websites and to fulfill our obligations under applicable terms of use/service; where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our websites and to provide you with content you access and request (e.g., to download content from our websites);
- Promoting security of our websites: We process your Personal Data by tracking use of our websites, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the systems and applications used for our websites and in protecting our rights and the rights of others;
- Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
- Handling contact and user support requests: If you fill out a “Contact Me” web form or request user support, or if you contact us by other means, we process your Personal Data to perform our contract with you and to the extent, it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
- Managing event registrations and attendance: We process your Personal Data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you, to perform of our contract with you;
- Developing and improving our websites: We process your Personal Data to analyze trends and to track your usage of our websites and interactions with our emails to the extent it is necessary for our legitimate interest in developing and improving our websites and providing our users with more relevant and interesting content;
- Registering office visitors: We process your Personal Data for security reasons, to register visitors to our offices and to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our offices and our confidential information against unauthorized access.
- Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
- Providing our mobile apps: We process your Personal Data to perform our contract with you for the use of our mobile apps and to fulfill our obligations under applicable terms of use/service. When you create a user from Configurator web-app, we may require that you provide us your contact information, such as your name, company name, phone number, email address, profile image, and this information is used in our Lifesherpa app.
Where we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.
6. Who do we share Personal Data with?
We may share your Personal Data as follows:
- With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support, and data enrichment for the purposes and pursuant to the legal bases described above; such service providers comprise companies located in these countries: USA, India, Romania. Some of the providers are Google, Amazon, Twilio and Zoho.
- If you use our websites to register for an event or webinar organized by one of our affiliates, with the affiliate to the extent this is required on the basis of the affiliate’s contract with you to process your registration and ensure your participation in the event; in such instances, our affiliate will process the relevant Personal Data as a separate controller and will provide you with further information on the processing of your Personal Data, where required
- If you attend an event or webinar organized by us or download or access an asset on our website, with sponsors of the event, if required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not wish for your information to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with Section 9 below;
- With sponsors of contests or promotions for which you register;
- With third-party social media networks, advertising networks and websites, which usually act as separate controllers, so that 3r Behavioral Solutions can market and advertise on third-party platforms and websites;
In individual instances, with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in countries in which we operate (USA) who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data; - With affiliates within the 3r Behavioral Solutions, Inc corporate group and companies that we acquire in the future when they are made part of the 3r Behavioral solutions corporate group, to the extent such sharing of data is necessary to fulfill a request you have submitted via our websites or for customer support, marketing, technical operations, and account management purposes. 3r Behavioral Solution is currently the only operating company in the group.
- If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by the third party, with such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.
Any Personal Data or other information you choose to submit in communities, forums, blogs or chat rooms on our websites may be read, collected and used by others who visit these forums, depending on your account settings.
For further information on the recipients of your Personal Data, please contact us by using the information in the “Contacting us” section, below.
7. Children
Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16 If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contacting us” section, below, and we will take steps to delete such Personal Data from our systems.
8. How long do we keep your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the “Purposes for which we process Personal Data and the legal bases on which we rely” section, above). We determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
After the expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
For further information on applicable data retention periods, please contact us by using the information in the “Contacting us” section, below.
9. Your rights relating to your Personal Data
9.1 Your rights
You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws and, in particular, if you are located in the EEA, these rights may include:
- To access your Personal Data held by us (right to access);
- To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification);
- To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
- To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing);
- To transfer your Personal Data to another controller, to the extent possible (right to data portability);
- Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”). Automated
- Decision-Making currently does not take place on our websites; and
- To the extent we base the collection, processing, and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
If you are a resident of California, under the age of 18 and have registered for an account with us, you may ask us to remove the content or information that you have posted to our websites. Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another visitor to our websites.
9.2 How to exercise your rights
To exercise your rights, please contact us by using the information in the “Contacting us” section, below. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of a 3r Behavioral Solutions customer, we recommend you contact your company’s system administrator for assistance in correcting or updating your information.
Some registered users may update their user settings, profiles, organization settings, and event registrations by logging into their accounts and editing their settings or profiles.
To discontinue your account and/or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in the “Contacting us” section, below.
9.3 Your rights relating to Customer Data
As described above, we may also process Personal Data in the role of a processor (see the “Responsible 3r Behavioral Solutions entity” section above). If your data has been submitted to us by a 3r Behavioral Solutions customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly. Because we may only access a customer’s data upon instruction from that customer, if you wish to make your request directly to us, please provide us the name of the 3r Behavioral Solutions customer who submitted your data to us. We will refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe.
10. How we secure your Personal Data
We take precautions including organizational, technical and physical measures to help safeguard against the accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use.
While we are GDPR compliant and follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites and applications, please contact us by using the information in the “Contacting us” section, below.
11. Changes to this Privacy Statement
We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements and other factors. If we do, we will update the “effective date” at the top of this Privacy Statement. If we make an update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.
We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing, and sharing of your Personal Data.
12. Contacting us
To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement or our privacy practices please fill out this form or mail us at:
3r Behavioral Solutions Data Protection Officer
12100 Sunset Hills Rd suite 150,
Reston, VA 20190
Data Protection Officer Email: support@3rbehavioralsolutions.com
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.