Privacy Policy

1. TYPES OF PERSONAL INFORMATION WE COLLECT, PURPOSES AND METHODS OF COLLECTION

To provide and operate our Services, we may collect and process the following types of Personal Information:

1.1 Your Contact Information.

When you contact us using the "contact us" form on our website, when applying on our website for partnership inquiries, or otherwise using the Services, you may voluntarily provide us with your name, your company name, business email address, telephone number, or other details. Such data may be processed for the purposes of providing the Services, ensuring the security of the Services, and communicating with you (including by sending you our or our partners' newsletters and promotional offers, as described in section 1.4 below).

1.2 Recruitment.

The website allows you to submit your resume for open positions with our Company. We may process information that you provide us as part of any HR recruitment process you undergo with the Company. We will collect and use Personal Information to help assess your skills and your suitability to the relevant position, and for complying with legal requirements to which we are subject. We may also use such data to contact you if we believe any career opportunities with the Company may interest you. We may process any information you choose to include in your resume, including but not limited to, name, email address, telephone number, generally common information in provided in resumes, skills, work experience, education, profile photo, URL of your LinkedIn profile, references, certifications and qualifications and other relevant information associated with your candidacy assessment. Please note that if you are providing us with any information of third parties, such as references, you are responsible to notify them of this fact and obtain their consent for use of their Personal Information.

1.3 Third Parties.

Your personal data can also originate from other sources, such as LinkedIn profiles, recruitment agencies, headhunters, and referrals. Moreover, if we promote our Services using third party properties, such as social networks, search engines and so forth, we may also receive Personal Information (namely, IP addresses, online identifiers and other pseudonymous identifiers) regarding your interaction with our ads or Services. If we receive such information, we will process it to display more relevant ads and improve our Services.

1.4 User Communications.

When you send email or other communication to the Company, we may retain those communications in order to process your inquiries, respond to your requests and improve our Services. We use this Personal Information to send you reminders and updates in respect of the Services. We may also send you newsletters and promotional communications. In order to receive any communications from us you will be asked to opt-in and consent to such receipt, and you may revoke such consent at any time by contacting us through the Website for this purpose or by following the “unsubscribe”, “opt-out” or “e-mail preferences” or a similar link contained in the communications you receive from us.

1.5 Technical Information.

When you use the Services, we automatically receive and record information from your browser, including without limitation information and statistics about your online/offline status, your IP address, geolocation data (including country and city), browser identifiers, internet service provider, connection speed, search history, type of browser, your regional and language settings and software and hardware attributes. Some of this data, or the combination thereof may be considered Personal Information. Our systems automatically record and store technical information regarding the method and nature of your use of the Services, including through the use of cookies and other tracking technologies (see Section 7 below). An IP address is a numeric code that identifies your browser on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. The Company uses the Personal Information identified in this Section in order to understand the usage trends and preferences of our users, including recent visits to our Services and how you move around different sections of our Services, for analytics purposes, to make our Services more intuitive, and in order to identify fraud, abuse or similar activities.

1.6 Legal and compliance

We may use certain Personal Information to prevent potentially prohibited or illegal activities, such as but not limited to fraud, misappropriation, infringements, identity thefts and any other misuse of the Services, to enforce our legal rights and terms and conditions, to protect the security or integrity of our databases, and to take precautions against legal liability.

2. Legal BASES

Where applicable, we rely on one or more of the following lawful bases we for processing Personal Information:

1. You gave us your consent to the processing of your personal data (for one or more specific purposes) including through our website(s) cookie notice and consent management mechanism in order to implement tracking technologies. You may withdraw your consent at any time by using the cookie preference settings (further information can be found in Section 7), or by contacting us at privacy@bestchoice.com.
2. Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
3. We process Personal Data about individuals in accordance with our legitimate interests, such as, as applicable, to improve and enhance our Services, to understand how our Services are used, to optimize our marketing, advertising, customer services and support operations, to maintain the security of our Services, to enforce any applicable terms and conditions of service, and to protect or defend the Services and our rights.
4. Processing is necessary for compliance with a legal obligation to which we are subject.

3. CATEGORIES OF RECIPIENTS WE DISCLOSE PERSONAL DATA TO; PURPOSES OF DISCLOSURE

We may disclose your Personal Information internally within our group, or externally to third parties that help us maintain, improve and provide our Services, (for example, we share data with AWS Inc. who provide us with cloud storage services). We require these parties to process Personal Information in compliance with this Privacy Policy, applicable laws, and subject to security and other appropriate safeguards (including, where applicable, with respect to the cross-border transfer of personal data, as described below).

The categories of such third-party recipients includes:

1. Entities Within the Company’s Group: We may share your Personal Information internally within the Company’s Group, as necessary for administrative, management or other business-relates purposes, to operate our Services, to communicate with you, to offer and provide our Services to you, etc.
2. Service Providers: We may disclose Personal and non-Personal Data with our affiliated companies and additional third parties that perform services on our behalf, such as hosting, storage, analytics, advertising and marketing, database management, user engagement, cyber and data security. We may also share such data with our business, legal and financial advisors.
3. Advertisers: We partner with third parties to either display advertising on our Services or to manage our advertising on other websites or apps. We and our third-party advertisers use tracking technologies to gather information about your activities on our Services and other websites and apps in order to provide you with advertising based upon your browsing activities and interests. For further information on our and our advertisers' use of tracking technologies please refer to the 'Cookies' section below.
4. Legal and Regulatory Entities: We may disclose any type of Personal Information, in case we believe, in good faith, that such disclosure is necessary in order to enforce our policies, take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, protect the security or integrity of the Service and protect the rights and property of the Company. We may also disclose your Personal Information when requested by legal or regulatory authorities in response to a verified request relating to terror acts, criminal investigations or similar illegal activity, or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.
5. Mergers and Acquisitions: We may use and disclose any of the Personal Information in connection with any merger, sale, transfer of any of our assets, investment, acquisition, bankruptcy, or similar event or any corporate transaction with any type of entity, whether public, private, foreign or local.

4.SECURITY AND DATA RETENTION

4.1 Retention. We will retain Personal Information for as long as reasonably necessary for the purposes for which it was collected, or held to comply with any applicable legal or ethical reporting or legal document retention requirement. We will also retain Personal Information to meet any audit, compliance and business best-practices. Personal Data that is no longer retained will be deleted or anonymized. Non-personal, non-identifiable, metadata and statistical information concerning the use of our Services are retained by Company as long as the Company determined it is required.

4.2 Security. We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to protect your Personal Information, we cannot ensure or warrant the complete security and privacy of your Personal Information or other content you transmit using the Service, and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the Personal Information you choose to disclose.

5. INTERNATIONAL DATA TRANSFERS

5.1 The servers on which the Services are hosted and/or through which the Services are processed may be outside the country from which you access the Services and may be outside your country of residence. Some of the uses and disclosures mentioned in this Privacy Policy involve the transfer of your Personal Information to various countries around the world that may have different levels of privacy protection than your country. However, Exon is committed to protect Personal Information in accordance with legal and privacy requirements, and applies appropriate lawful mechanisms and contractual terms requiring adequate data protection to ensure Personal Information continues to be protected in the jurisdiction to which such data is transferred.

In case of a Personal Information transfer outside of the EEA or the UK we will, in the absence of an EC Adequacy decision relevant to the destination country or to the transfer, seek to rely on appropriate safeguards such as entering into appropriate EC approved standard contractual clauses (see https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj) or a similar approved transfer mechanism (such as the EU-US Data Privacy Framework), as applicable.

6. YOUR RIGHTS

Depending on your jurisdiction, you may exercise any of the following rights, by contacting us at: privacy@bestchoice.com. We will handle these requests in accordance with applicable law, including by requesting you further details to verify your identity and applying relevant exemptions. Please note that exercise of some of those rights may have some consequences in your application as a candidate. In the context of the Services we do not use any automated decision-making related to your Personal Data.

6.1 Right of Access and Rectification.

You have the right to know what Personal Information we collect about you and to ensure that such data is accurate and relevant for the purposes for which we collected it. We allow our users the option to access and obtain a copy of their Personal Information and to rectify such Personal Information if it is not accurate, complete, or updated.

6.2 Right to Delete, Restrict or Object to Processing.

Under certain circumstances, you have the right to delete your Personal Information or restrict(other than for storage purposes) or cease its processing.

6.3 Right to Withdraw Consent.

Where we rely on consent to process Personal Information about you, you have the right to withdraw your consent to the collection, use or processing of your Personal Information at any time. Exercising this right will not affect the lawfulness of processing your Personal Information based on your consent before its withdrawal.

6.4 Right of Data Portability.

Where technically feasible, you have the right to ask to transfer your Personal Information in accordance with your right to data portability.

6.5 Opt-Out of Sharing for Cross-Contextual Behavioral Advertising.

You have the right to opt-out of the “sharing” of your Personal Information for “cross-contextual behavioral advertising” (all as defined under the CCPA), often referred to as “interest-based advertising” or “targeted advertising”.

6.6 Right to Non-Discrimination.

You have the right not to be subject to unlawful discrimination by us for exercising any of the rights above.

Please be aware that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain Personal Data about you.

For EU and UK residents: If you think we have infringed data protection laws, you also have the right to lodge a complaint with a data protection supervisory authority in the EEA country in which you live or work, or where you think we have infringed data protection laws, or with the UK ICO, as applicable to you.

Please be aware that only you, or someone legally authorized to act on your behalf, may make a request related to Personal Information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

In some jurisdictions, you have the right to appeal a rejection to your request. The appeal request shall be submitted to privacy@bestchoice.com.

7. COOKIES

7.1 In order to collect the data described herein we may use temporary cookies that remain on your browser for a limited period of time. We may also use persistent cookies that remain on your browser until the Company’s Services are removed, in order to manage and maintain the Services and record your use of the Services. Cookies by themselves cannot be used to discover the identity of the user. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. Cookies do not damage your browser. Most browsers may allow you to block cookies but you may not be able to use some features on the Services if you block them. You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want to accept it or not). We may also use web beacons via the Services to collect information. Web beacons or “gifs”, are electronic images that may be used in our Services or in our emails. We use Web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon. For more information on how we use cookies, please see our Website Cookie Policy available at: https://www.exon-media.com/Cookies-policy. To change your cookie preferences, please click here.

8. MINORS

We do not knowingly contact or engage with individuals under the age of majority ("Minors"), and will not knowingly collect, use or process Personal Information of Minors without parental or legal guardianship consent. By using the Services, you represent that you are at least the age of majority in your state, province or country of residence, If you have reason to believe that a Minor's Personal Information has been provided us without parental consent, please contact us at the address given below and we will endeavor to delete that personal information from our databases.

9. THIRD PARTIES' WEBSITES AND SERVICES

While our Services may contain links to other websites, content, information, materials, products, services and/or commercials, we are not responsible for their privacy practices, and encourage you to pay attention when you interact with any such website, service or application of such third parties, and to read the privacy policies of each and every website, service and application you interact with. We are not responsible for the content of those third-party websites, content, information, materials, products, services and/or commercials and you visit them at your own risk, This Privacy Policy applies only to our Services.

10. ADDITIONAL DISCLOSURES TO U.S. RESIDENTS

Most of the statements, rights and obligations under this part are common to all US Privacy Laws and apply to you only to the extent determined in the applicable law according to your residency.

A. Collection, Disclosure and Sharing of Personal Information

In the preceding 12 months, we have collected the following Personal Information:

Sources of Information

In the preceding 12 months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

1. Directly, through your activity on our Services: For example, from forms you complete on our Websites.
2. Indirectly from you: We track your activities across the internet, for example, when you view or interact with certain content, web page or ad, or when we collect your usage data automatically from measurement tools such as those implemented on our websites.
3. From third-parties: for example, from advertisers, service providers who assist us in performing the Services for our customers, internet service providers, data analytics providers, social networks, recruitment agencies, and data brokers.

We do not “Sell” Personal Information, but we do “Share” Personal Information about you (in the meaning assigned to the terms "sell" and "share" under US Privacy Laws).

In the preceding twelve (12) months we have shared and disclosed your Personal Information, as described below:

When we disclose Personal Information, we ensure that the recipient only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the Personal Information they receive, and where applicable, to use it for pre-agreed purposes only. We also take measures to contractually ensure any recipient complies with applicable data protection laws.

Purposes for Collection, Use, & Sharing

In addition to the practices detailed in Section 1 of the Privacy Policy, we also use and disclose the Personal Information we collect for the following commercial and business purposes:

1. Auditing related to our interactions with you;
2. Legal compliance;
3. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution;
4. Debugging;
5. Performing services (for us or our partners);
6. Internal research for technological improvement;
7. Internal operations;
8. Activities to maintain and improve our services
9. Other one-time or short-term uses.

To opt-out of sharing your personal information, as described above, please click here.

B. Requests Metrics

As required under the CCPA, we publish the following metrics to provide clarity on the requests we have received, and how we handled them, in the previous year (these metrics are compiles annually and refer to the period between July 1st of the previous year to July 1st of the following year):

C. Do Not Track Notices.

California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding its disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@bestchoice.com. Please note that we are only required to respond to one request per customer each year. You are also advised that Company does not respond to “Do Not Track” signals.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy. We will notify you about significant changes in the way we treat PII by sending a notice to the primary email address specified in your account or by placing a prominent notice on the Services. We encourage you to periodically review this Privacy Policy for the latest information about our privacy practices.

13. CONTACT US

If you have any questions about this Privacy Policy or concerns about the way we process your Personal Information, please contact us at privacy@bestchoice.com.