Privacy Notice

Effective date: February 28, 2024

B-SPOKE, LLC (“B-SPOKE,” “We,” “Us”) believes it is important that you understand how B-SPOKE collects, stores, shares and uses information from and about our website visitors, customers and vendors. We adhere to this notice listed on this website, www.bspokellc.com (“Website”), in respect to our collection, use and disclosure of personal and non-personal data collected through the Website or in the course of our business activities conducted elsewhere when we act as the controller of that data and when its processing is governed by the EU General Data Protection Regulation (GDPR). This notice does not apply to the information we collect and process in connection with our Consulting service. This notice does not apply to the information collected, stored, shared, or distributed by third-party sites. This notice may be updated from time to time.

Information We Collect Automatically

When you visit our Website, our server automatically collects certain browser or device generated information, which may in some cases constitute personal data, including but not limited to:

  • your domain;

  • your IP address;

  • your date, time and duration of your visit;

  • your browser type;

  • your operating system;

  • your page visits;

  • information from third parties;

  • other information about your computer or device;

  • Internet traffic.

We do not use this automatically collected information to try to identify you by name, and we do not associate it with the information you provide voluntarily, as detailed below.

Information You Provide

In order to access or use certain portions of the Website or enjoy the full functionality of the Website, or otherwise in conducting business with us or seeking to conduct business with us, you may be prompted to provide certain personal data to us in the following ways:

  • by filling in forms (for example, a ‘Contact Us’ form) on our Website or at a trade show or anywhere else we conduct business;

  • by downloading documentation from our Website;

  • by subscribing to newsletters or other communications;

  • by purchasing products or services;

  • by corresponding with us or our affiliates by phone, e-mail or otherwise using our contact details; or

  • by applying for a job, work placement or internship over our recruitment platform, in relation to which you should also refer to the specific privacy notices made available to you during the recruitment process.

Typically, the personal data you give us may include name, title, business affiliation, business address, telephone number, billing information such as credit card information or ACH details, and email address, and any personal details required to resolve any enquiries or complaints.  Where you are applying for a job, work placement or internship, you will be asked to provide certain additional information, for example about your education, employment history and right to work, pursuant to a specific privacy notice for job candidates.

This information is required to enter into a contract with you (such as in anticipation of an employment contract or a services agreement) or provide services at your request, and failure to provide any information may result in our inability to provide requested services or products, or consider your application for employment.

We may also obtain personal data about you from third parties, including publicly accessible sources.

Cookies

Our Website uses cookies.  More information about our use of cookies can be found in the “Information We Collect Automatically” section of our main Privacy Policy above.

Use of Personal Data

The following is an overview of our purposes for using your personal data.  Additional details on how we process your personal data may be provided to you in a separate notice or contract.

All processing (i.e. use) of your personal data is justified by a “condition” for processing. In addition, processing of sensitive personal data (such as information provided for a recruitment application) is always specifically justified. In the majority of cases, processing will be justified on the basis that:

  • the processing is necessary to perform a contract with you or take steps to enter into a contract at your request;

  • the processing is necessary for us to comply with a relevant legal obligation;

  • the processing is in our legitimate interests, subject to your interests and fundamental rights, and notably our legitimate interest in using supplier, customer and Website user data to conduct and develop our business activities with them and with others; or

  • you have consented to the processing.

We use the personal data we collect to:

  • conduct and develop our business with you and with others;

  • process, evaluate and complete certain transactions involving the Website, and more generally transactions involving BSPOKE products, services and affiliates;

  • operate, evaluate, maintain, improve and develop the Website (including by monitoring and analyzing trends, access to, and use of the Website for advertising and marketing;

  • evaluate, improve and develop our products and services generally;

  • customize our Website to users’ needs;

  • engage you about events, promotions, the Website and B-SPOKE products and services;

  • provide you with documentation or communications which you have requested;

  • correspond with users to resolve their queries or complaints;

  • support and manage a recruitment, work placement or internship process, including considering applications and making offers;

  • provide you with any services or products you request;

  • send you marketing communications, where it is lawful for us to do so;

  • protect and ensure safety of the Website, BSPOKE confidential and proprietary information, and BSPOKE employees;

  • manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations.

B-SPOKE will not sell or rent your personal data to third parties.

Disclosure of Personal Data

From time to time it will be necessary to share your personal data with our affiliates and affiliated businesses. B-SPOKE may appoint third party service providers (who will operate under our instructions) to assist us in providing information, products or services to you, in conducting and managing our business, or in managing and improving our products, services or the Website. B-SPOKE may share your personal data with these affiliates and third parties to perform services that the third parties have been engaged by B-SPOKE to perform on B-SPOKE’s behalf, subject to appropriate contractual restrictions and security measures, or if we believe it is reasonably necessary to prevent harm or loss, or it believes that the disclosure will further an investigation of suspected or actual illegal activities.

B-SPOKE reserves the right to share any information that you provide which is not deemed personal data or is not otherwise subject to contractual restrictions.

If your personal data is transferred outside the EU to other B-SPOKE group companies or to third party service providers, we will take steps to ensure that your personal data receives the same level of protection as if it remained within the EU, including by entering into data transfer agreements, using the European Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield.  For transfers to B-SPOKE in the US, we rely on European Commission approved Standard Contractual Clauses, which protect personal data transferred between B-SPOKE entities. You have a right to obtain details of the mechanism under which your personal data is transferred outside of the EU by contacting GDPR@BSPOKEworldwide.com.

We may share your personal data with third parties in connection with potential or actual sale of our company or any of our assets, or those of any affiliated company, in which case personal data held by us about our users may be one of the transferred assets.

Marketing

Where lawful to do so, and subject to your consent where required, we may communicate with you by email or social media platforms to tell you about our products and services. If you wish to opt-out of receiving marketing communications, please use the ‘unsubscribe’ link provided in our emails, leave sponsored groups on social platforms, or otherwise contact us directly at info@bspokellc.com we will stop sending you communications.

Security

B-SPOKE aims to safeguard and protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and B-SPOKE utilizes and maintains certain reasonable processes, systems, and technologies to do so. However, you acknowledge that no transmission over the Internet is completely secure or error-free, and that these processes, systems, and technologies utilized and maintained by B-SPOKE are subject to compromise. Accordingly, we cannot be held responsible for unauthorized or unintended access that is beyond our control.

Retention of your Personal Data

We apply a general rule of keeping personal data only for as long as required to fulfill the purposes for which it was collected.  However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.

In specific circumstances, we may also retain your personal data for longer periods of time corresponding to a statute of limitation so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

External Links

The Website may contain links to third-party sites. Since B-SPOKE does not control nor is responsible for the privacy practices of those websites, we encourage you to review the privacy policies of these third-party sites. This notice applies solely to personal data collected by our Websites or in the course of our business activities.

Your Rights

We will take steps in accordance with applicable legislation to keep your personal data accurate, complete and up-to-date.  You are entitled to have any inadequate, incomplete or incorrect personal data corrected (that is, rectified).

You also have the right to request access to your personal data as well as additional information about the processing.

In the event your personal data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Further, you are entitled to object to the processing of your personal data and to have your personal data erased, under certain circumstances.

As from February 28, 2024, you also have the following additional rights:

Data portability – where we are relying (as the legal basis for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal data is processed by automatic means, you have the right to receive all such personal data which you have provided Us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.

Right to erasure – you are entitled to have your personal data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below) or where personal data is unlawfully processed.

Right to restriction of processing – you have the right to restrict our processing of your personal data (that is, allow only its storage) where:

  • you contest the accuracy of the personal data, until we have taken sufficient steps to correct or verify its accuracy;

  • where the processing is unlawful but you do not want us to erase the personal data;

  • where we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise or defence of legal claims; or

  • where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.

Where your personal data is subject to restriction we will only process it with your consent or for the establishment, exercise or defence of legal claims.

Right to object to processing (including profiling) based on legitimate interest grounds – where we are relying upon legitimate interests to process personal data, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

Right to object to direct marketing (including profiling) – you have the right to object to our use of your personal data (including profiling) for direct marketing purposes, such as when we use your personal data to invite you to our promotional events.

You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable law.

Please contact Us as indicated in Contact Information if you wish to exercise any of your rights, or if you have any enquiries or complaints regarding the processing of your personal data.

Changes to this Notice

Any changes or updates we may make to this Notice will be posted on this page in advance.  If we have your email on file, as described in the Marketing Section, we will notify you in advance of any changes to this Notice that are material or may impact you. For other changes, please check back frequently to see any updates or changes to this Notice.

Contact Information

If you have any questions in relation to this notice or you wish to exercise any of your rights, please contact us at: info@bspokellc.com.