PRIVACY POLICY

Bonsai Data Solutions, LLC PRIVACY POLICY

Updated February 4th, 2020

Bonsai Data Solutions, LLC (the “Company”) is committed to maintaining robust privacy protections for its users. Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Service. For purposes of this Agreement, “Site” refers to the Company’s website, which can be accessed at: bonsai.llc. “Service” refers to the Company’s services accessed via the Site, in which users can read information regarding our professional data solutions & services, and request further details from us on appointment. The terms “we,” “us,” and “our” refer to the Company. “You” refers to you, as a user of our Site or our Service. By accessing our Site or our Service, you accept our Privacy Policy and Terms of Use, and you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy.

I. INFORMATION WE COLLECT
We collect “Non-Personal Information” and “Personal Information.” Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. Personal Information includes your email, first name, last name, company of employment, role or business title at said company, business category, and service type your inquiry pertains to; all of which you submit to us through the our contact submission forms throughout the website.

1. Information collected via Technology

To activate the Service you do not need to submit any Personal Information other than your email address. To use the Service thereafter, you do not need to submit further Personal Information. However, in an effort to improve the quality of the Service, we track information provided to us by your browser or by our software application when you view or use the Service, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Service, the time and date of access, and other information that does not personally identify you. We track this information using cookies, or small text files which include an anonymous unique identifier.

COOKIES

A cookie is a small data file that is written to your computer’s hard drive by your web browser. A cookie file can contain and/or automatically collect information, such as a user identification code or IP address, which a website will use to track the pages and number of times you have visited. The data read from these cookies may be linked to personally identifying (PII) and non-personally identifying (non-PII) information.

We may use a variety of methods, including “cookies” to collect information. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at: http://www.allaboutcookies.org.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that advertisements you see online are more relevant to you and your interests.

Bonsai Data Solutions, LLC collects cookies on our Sites and/or Services to capture information about page visits (e.g. “performance cookies.”) This information is anonymous and Bonsai Data Solutions, LLC uses this information only internally – to deliver the most effective content to our visitors. Information from the cookie is used to gauge page popularity, analyze traffic patterns on our Sites and/or Services and guide development of other improvements to our Sites and/or Services. Without them, Bonsai Data Solutions, LLC may not be able to provide core Site functions and features to you, and the Site would not operate as well as you or Bonsai Data Solutions, LLC would like. These cookies collect and use information such as your server preferences, single-session data and corresponding identifier, web beacons and log files (detailed below), and other credential-related information. For EU individuals, essential cookies also help inform Bonsai Data Solutions, LLC whether you require, or have already been served, an affirmative consent request in connection with the GDPR. Essential cookies include analytics cookies, which provide us data that allow Bonsai Data Solutions, LLC to better understand its users and improve the Site based on what we have learned from that data.

Bonsai Data Solutions, LLC does not require that you accept cookies and/or you may withdraw your consent to our use of cookies at any time by adjusting your browser’s privacy settings, however, some functionality on our Sites (e.g. “functionality cookies”) and Services may be disabled if you decline to accept cookies ( e.g. “necessary cookies”).

By using the Sites and Services, you consent to the placement of the cookies referenced above. You can, however, set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. You may also change your cookie settings through preference options in our Sites and/or Services, where applicable. We will indicate that upon selecting your preferences, that we will use a cookie to remember your preferences.

Bonsai Data Solutions, LLC never gives away information about our users. If you choose to provide Personal Information about yourself, Bonsai Data Solutions, LLC will use this information only to communicate directly with you. Bonsai Data Solutions, LLC will not sell, rent or otherwise disclose that information to third parties unless such disclosure is necessary for the purposes set forth in this Policy, by law or a policy or notice contained or associated with a specific Site(s) and/or Service(s).

ANALYTICS TOOLS

Bonsai Data Solutions, LLC uses the third party analytics technology Google Analytics to collect non-personal information in the form of various usage and user metrics when you use our online Sites and/or Services. This tool collects and analyzes certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and inquiry history, mobile unique device ID, and other similar information.

The third party analytics companies who collect information on our Sites and/or Services and other online products and/or services may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect and use information under their own privacy policies.

You may opt out of Google Analytics by visiting the Google Analytics opt-out page.

Notice to EU Individuals: As outlined in this Privacy Statement, Bonsai Data Solutions, LLC will not process your user information without a lawful basis to do so, as such bases are defined in Article 6 of the GDPR. In general, Bonsai Data Solutions, LLC will process your user information on the legal bases of consent, contract (if you have entered into an agreement with us and such processing is a necessary part thereof), or legal obligation (as noted above). Bonsai Data Solutions, LLC may also process certain user information on the basis of the following legitimate interests, provided that such interests are not overridden by your privacy rights and interests: delivering and continuing to develop and improve the Site, learning from your behavior on the Site (e.g., analyzing traffic) to better serve you and other Site users, helping us modify or enhance the Site and its content, receiving insight as to what users do (and don’t) like about our Site or aspects thereof, and providing a stable, consistent, and secure user experience in connection with the Site.

2. Children’s Privacy

The Site and the Service are not directed to anyone under the age of 13. The Site does not knowingly collect or solicit information from anyone under the age of 13, or allow anyone under the age of 13 to sign up for the Service. In the event that we learn that we have gathered personal information from anyone under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at requests@bonsai.llc.

II. HOW WE USE AND SHARE INFORMATION
Personal Information: Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. We do share Personal Information with vendors who are performing services for the Company, such as the servers for our email communications who are provided access to user’s email address for purposes of sending emails from us. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy. In general, the Personal Information you provide to us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, and inform users about promotional offers. We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms of Service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law. We do not sell the personal information you provide us, and we will not share your personal information with third parties for marketing purposes.

Non-Personal Information: In general, we use Non-Personal Information to help us improve the Service and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Site. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion. In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.

III. HOW WE PROTECT INFORMATION
We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. We protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks.

IV. YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION
You have the right at any time to prevent us from contacting you for marketing purposes. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. You can also indicate that you do not wish to receive marketing communications from us in the Do Not Track Me page of our Site. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the Do Not Track Me page of our Site, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.

V. LINKS TO OTHER WEBSITES
As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Service. Therefore, this Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

VI. CHANGES TO OUR PRIVACY POLICY
The Company reserves the right to change this policy and our Terms of Service at any time. Non-material changes will take effect immediately. You should periodically check the Site and this privacy page for updates.

VII. CONTACT US
If you have any questions regarding this Privacy Policy or the practices of this Site, please contact us by sending an email to requests@bonsai.llc Last Updated: This Privacy Policy was last updated on January 30th, 2020.

VIII. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
The California Consumer Privacy Act (“CCPA”) grants residents of the State of California certain privacy rights in their personal information. This Privacy Notice for California Residents (“Notice”) supplements the terms of our Privacy Policy explained above and should be read in conjunction with the terms of our Privacy Policy. This Notice only applies to visitors and users of our website who are California residents (herein after “you” or “consumer”).

Information We Collect

The information we obtain from visitors to our Site fall into two distinct categories—the personal information that visitors provide us and technical information provided by the browser of the computer, tablet or mobile device used when visiting our Site. The information immediately below identifies categories or examples of personal information covered by the CCPA, and identifies categories of information that we have collected from visitors to our website in the past 90 days:

We do collect: Information on a consumer’s interaction with our Site, physical location data of Site visitors, unique personal identifier, online identifier, and Internet Protocol address.

For information inquiries, we collect: A real name, alias, professional or employment-related information, and an email address.

For businesses with whom we enter into a formal business contract, we collect: a name, signature, mailing address, email address, telephone number, credit card number, debit card number, or other financial information.

We do not collect: Records of personal property, products or services purchased, genetic, physiological, behavioral, and biological characteristics,sensory data, Non-public education information, information reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes, Protected classification characteristics under California or federal law.

Your CCPA Privacy Rights

The CCPA provides California residents with the right to request that we disclose:

Personal information collected: categories, specific pieces, category of sources, commercial purposes

Third parties: With whom we have shared your personal information, specific categories of third parties, and our business purpose for sharing such information.

Your rights: to request that we delete collected personal information, subject to exceptions outlined below, your right to non-discriminatory treatment.

Requests to Delete Personal Information

You have the right to request that we delete any of your personal information collected from you. Once we receive and confirm your request, we will delete the information from our records unless an exception applies. The CCPA provides that we are not required to comply with a request to delete personal information if the information is necessary for Us to:

complete the transaction for which the information was collected

provide a service you requested

perform a contract with you

take anticipated actions due to our ongoing business relationship with you

detect security incidents, protect against deceptive, fraudulent, or illegal activity

comply with the California Electronic Communications Privacy Act

exercise another right provided by law

enable solely internal uses that are reasonably aligned with consumer expectations

How To Exercise Your Privacy Rights

You can exercise these rights by sending an email to requests@bonsai.llc. You may make the request on your own behalf or on behalf of your minor child. Another person who is legally authorized to act on your behalf may also submit a request for you. We will promptly acknowledge receipt of your request and begin our verification process. Before we respond to any request involving personal information, the CCPA requires that we confirm the identity of the person making the request, and if the request is made on behalf of another person. We reserve the right to deny any request where we are unable to satisfactorily confirm your identity. We will attempt to verify your identity by matching any information provided in your request against the personal information already in our possession. If you have authorized someone to make a request on your behalf, we will attempt to verify the identity of that person. This process does not require that you establish any type of account with us or sign up to receive any of our services.

During our verification process, we may request additional information from you. Any information provided to us during our verification process will only be used for purposes of verifying your identity or the identity and/or authority of the person making the request. We will endeavor to respond within forty-five (45) days of receipt of your request. If we are unable to respond within that time, we will notify you of the reason and the additional time needed to make our response. The CCPA permits us to extend the time of our response by up to an additional 45 days. We are not obligated under the CCPA to respond to any request where compliance or disclosure would violate an evidentiary privilege under California law, or conflict with federal or state law. The CCPA, does not require that we provide personal information to a consumer more than twice in a twelve month period. Disclosures we make will only cover the twelve (12) month period preceding the request. We will not charge a fee to process or respond to your request and will provide information free of charge. Where a person’s requests are repetitive, unfounded or excessive, the CCPA authorizes us to either charge a reasonable fee that takes into account our administrative costs, or refuse to act on the request and notify the person making the request our reason for refusing the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. For example, we will not deny you services, charge you a different price, or impose a penalty for the exercise of your CCPA rights.

IX. PRIVACY NOTICE FOR VISITORS FROM THE EUROPEAN UNION
On May 25, 2018 the General Data Protection Regulation (“GDPR”) went into effect in the European Union (“EU”). The GDPR extends certain rights to natural persons involving the privacy of their personal information. Bonsai Data Solutions, LLC is the data controller for any personal information provided via our website. Any information that you provide to us will be stored in the United States; we do not intend to transfer your personal data to another country or international organization. We will retain any personal information that you provide via our website for 90 days from the date you provided or last updated that information, unless you request that information be deleted at an earlier date. If that information is subject to a litigation hold, or is required to assert or defend a legal claim, then we will hold that information until the claim or action is resolved.

Under GDPR, individuals are granted rights as follows: You have the right to ask what personal information we have about you in our possession. You have the right to obtain a copy of your personal data free of charge so long as it does not adversely affect the rights of others. We may charge a reasonable fee based on administrative costs for additional copies. The right of access includes the right to request that we update or correct your personal information in our possession.

You have the right to request that data be deleted or erased when it is no longer needed for the purposes for which it was collected or processed, when you withdraw your consent, when data is unlawfully processed, to comply with a legal obligation of the EU or a Member State, or when you object to the processing and we are unable to demonstrate compelling, legitimate grounds for the processing which overrides your rights and interests. Personal data does not have to be erased when it is necessary “for the establishment, exercise, or defense of legal claims.”

You have a right to restrict the processing of your personal data when you contest the accuracy of the personal data in our possession until we are able to verify its accuracy, you oppose its erasure and request restriction instead. You have the right to object to processing when it is based on a “legitimate interest” of the controller, a third party, or for processing that occurs for direct marketing purposes.

You have the right to withdraw your consent at any time by sending an email to: requests@bonsai.llc. You also have the right to lodge a complaint with the supervisory authority about our data privacy practices where you reside. You can exercise these rights by sending an email to: requests@bonsai.llc

We will review any requests we receive and attempt to respond in a timely manner. For security reasons, we may request specific information from you to help us confirm your identity before taking action on any request, and to ensure your right of access does not adversely affect the rights of others. We reserve the right to refuse to act on a request, or to charge a reasonable administrative fee when a request is unfounded or excessive because of its repetitive character.