Privacy Policy

Last Updated: March 1st, 2020.

Please find below a summary of how BOTTLENECK CART processes Personal Data.

We process the Personal Data of our Customers and our Platform Users as a data controller. We also act as a data processor – when our Customers engage us in data processing in order to enable them to carry out operations on that data using our tools and services

HOW DO WE PROCESS YOUR DATA? As a Data controller, we will process your Data to enable you to create an Account, to provide you with our Service, and if you agree, to send you marketing communication, which we may tailor to your interests.

WHY DO WE PROCESS YOUR DATA? We have the right to process your Data for different reasons. The most important one is that we need it to carry out the agreement concluded with you the moment you accept our Terms of Service and to enable you to use our Platform. There are also other reasons that require us to process the Data, e.g. preparing an answer to your queries or your consent to receive our newsletter.

WHO DO WE DISCLOSE YOUR DATA TO? We disclose your data only to service providers who support us in the role of data processors or separate data controllers.

YOUR RIGHTS. You have the right to access, rectify or erase your Personal Data as well as to complain about a supervisory authority. In some cases, you also have other rights, for example, to withdraw your consent for Data processing, to object to Data processing, and Data portability.

Please read the entire content of our Privacy Policy below, to fully understand how we will process your Personal Data and how you can exercise your rights connected to Data processing.

PRIVACY POLICY

This Privacy Policy describes how we protect the Personal Data of our Customers and Users. We appreciate the trust you put in us, and we assure you that we make every effort to give you full control over your Personal Data. Below we have described, as transparently as possible, the scope of data we process when providing the Service and the Platform, the purposes and methods of processing, security measures, and your rights connected with the processing of your Personal Data.

By using our Service or our Platform, you accept all rules applied by BOTTLENECK CART, so please read this Privacy Policy carefully beforehand. If you don’t agree to this Policy or can’t comply with it, you shouldn’t begin to use our Service or our Platform.

GLOSSARY OF BASIC CONCEPTS

Below you’ll find the list of basic concepts that will help you better understand this Policy:

Account – individual space provided to the Customer on the BOTTLENECK CART Platform (after logging in) for the purpose of using the Service.

Contacts – persons whose data (in particular Emails addresses) is processed using the Service, or to whom Customers send electronic communication (in particular Emails communication).

Customer – a person using our Service to conduct their commercial or professional activities, regardless of the legal form of such activities.

Data concerning activity within the Platform or Service – the data concerning your activity within the Service or Platform, data concerning your session, your device and operational system, browser, localization, and unique ID as registered and stored with the use of cookies or tracking scripts. This data includes in particular: browsing history clicks within the Platform, visits to the main page and subsections of the Platform, dates of creating an account and logging into the Account, the data related to the use of individual services in the Platform and Service, history and activities connected to our Emails communication with you.

Data provided as Account details – personal data given by the User in the “Account details” tab, consisting of first name, last name, company or organization, address, Emails address, phone number, country, time zone, payment information, industry, number of employees.

Personal Data – data of our Customers, data entrusted to us by our Customers for processing and data of our Users, processed about the use of the Service or Platform.

Platform – websites that are hosted by BOTTLENECK CART, especially domains listed under the address: www.bottleneckcorp.com Via the Platform the Customer can log in to their Account. 

Privacy Settings – space in the Customer Account where the Customer can manage their preferences of privacy protection and exercise their rights as data subjects.

Processing – operations performed on Personal Data such as collection, recording, storage, adaptation or alteration, disclosure, creating backup copies, and other operations necessary to provide the Service or use the Platform.

Registration Data – the data given in registration forms available in the Platform: Emails address, name.

Service – all services provided by BOTTLENECK CART electronically in the Software-as-a-Service model (SaaS), including in particular providing the Customer with the possibility of using the Account, managing the Data entrusted to BOTTLENECK CART for processing, and conducting marketing campaigns.

User – the person using the Platform.

Capitalized terms that are not expressly defined in this document have the meanings assigned to them in the BOTTLENECK CART Terms of Service.

WHO ARE WE? OUR CONTACT DETAILS.

BOTTLENECK CART as a data controller and data processor

Unless stated otherwise, we process your Personal Data as a data controller in connection with your use of the Service or the Platform. As such, we determine the purposes and means of the processing of Personal Data.

In some circumstances, we also process Data on your behalf. In these cases, you determine the scope of Data you want us to process and the purposes for which you use the Service. 

Our contact details:

Address:

BOTTLENECK CART Av. Homero 205 piso 10, Polanco V seccion, Miguel Hidalgo C.P. 11560, Ciudad De México.

Phone number: +52 1 55 4124-0528.

Email: info@bottleneckcorp.com.

To exercise your rights, give or withdraw consent, and talk about all security aspects of your Personal Data you can contact us via info@bottleneckcorp.com.

DATA PROTECTION OFFICER

BOTTLENECK CART has designated a Data Protection Officer, who you can reach out to about anything related to your Personal Data processing. You can easily contact our DPO:

Address:

BOTTLENECK CART Av. Homero 205 piso 10, Polanco V seccion, Miguel Hidalgo C.P. 11560, Ciudad De México.

Phone number: +52 1 55 4124-0528.

Email: info@bottleneckcorp.com.

HOW DO WE USE THE DATA? YOUR PERSONAL DATA AND HOW WE PROCESS IT.

The rules of how we process your Data, along with the purposes and scope of the processing vary depending on whether you are our Customer or Platform User. Below, we list the information about the data we process concerning the specific purposes we need it for.

To provide the Service or Platform While providing the Service or Platform, we carry out a set of operations that include: administrative activities related to concluding an agreement based on the acceptance of the Terms of Use, creating a Customer Account and Customer authentication within the Account, providing materials requested by Customers or Users (also those who do not have an Account but use our Platform), activities related to the performance of the Service, including sending you communication-related to use or functioning of the Service (in a particular system and transactional e-mails), providing Customer support, handling complaints and other requests, charging due to fees, seeking redress, and monitoring the quality of the Service and Platform.

FOR WHAT PURPOSES?

For analytical purposes. To keep statistics on the use of the Service and the Platform, helping us to improve the Service and the Platform, and to ensure network and information security, we process the following Data:

Emails address, or Data concerning activity within the Platform or Service.

To exercise legal claims. If necessary, to establish, exercise, or defend legal claims, we process the following data: Data provided as Account details, Data concerning activity within the Platform or Service necessary to establish a claim, other data necessary to support the claim, establish the scope of damage and other circumstances regarding the damage.

To answer your queries. To respond to your queries, petitions, and complaints, we may process the following Data: o Data provided as Account details, o Data concerning activity within the Platform or Service that’s the subject of your query, petition, or complaint, o data included in the query, petition, or complaint and the attached documents.

To conduct Customer satisfaction surveys. To verify Customer satisfaction with the Platform or Service, we may process the following Data: o Registration Data, o answers to our survey questions.

To prevent fraud and abuse. To monitor, prevent, detect, and combat fraud and abuse, including sending unsolicited content (SPAM), to protect our Customers against such abuse and to ensure network and information security, we may process the following Data: o Data provided as Account details, o Data concerning activity within the Platform or Service necessary to verify potential fraud or abuse, o Data entrusted by the Customer to provide the Service.

WHY DO WE PROCESS YOUR DATA? THE LEGAL BASIS.

To provide the Service or Platform

We process your data because it is necessary to enable you to use our Service or Platform. In other words, we need to process your Personal Data to enable you to sign up as our Customer or order our materials as our User. Otherwise, we wouldn’t be able to provide the Service or enable you to use the Platform.

For legitimate business interests

Below you’ll find a list of our legitimate interests.

For analytical purposes. We believe we have a legitimate interest in analyzing Service and Platform operations and Customer and User satisfaction. We consider processing this data beneficial to Customers and Users. We aim to constantly develop the Platform and to provide the Service of the highest quality of Service.

To exercise legal claims. We believe we have a legitimate interest in processing your Data if it’s necessary to exercise claims concerning the use of the Service or the Platform that’s unlawful or incompatible with the Terms of Service or to defend ourselves against such claims.

To answer your queries. We believe we have a legitimate interest in replying to petitions and queries made through one of the available channels. We consider processing this Data beneficial for you because it allows us to help you and respond to your queries.

To conduct customer satisfaction surveys. We believe we have a legitimate interest in verifying if our Customers and Users are satisfied and what would help us improve the quality of the Service and the Platform.

To prevent fraud and abuse. We believe we have a legitimate interest in conducting necessary verification to detect and prevent potential fraud and abuse, including spam detection. We understand processing this Data is beneficial for all parties involved, especially for you and your subscribers, because it allows us to set up precautions, protecting you and your subscribers against third parties sending malicious software or attempting fraud.

To send you marketing communication

We have a legitimate interest in analyzing how our Customers and Users use our Service and Platform, to improve and expand our customer base.

Users of the Platform who have expressed their interest in receiving marketing communication to their Emails address give us their free, specific, informed, and unambiguous consent. Hence, we have inferred that they would have a reasonable expectation to receive such communication. At the same time, they expect that the communication we will send should be consistent with their interests. Personalized marketing communication allows our Customers to use our Service more effectively and benefit from our attractive offers.

For profiling, we use only the Data our Customers or Users provide us with or the Data concerning their activity within the Platform or Service. We’re only interested in what you do on our Platform or when you use our Service, and not what you do on other websites. That’s why we decided that our interests are justified, legitimate, and at the same time, they don’t violate the rights or freedoms of our Users or Customers, which may override them.

WHO DO WE DISCLOSE YOUR DATA TO?

We make sure that our Customers and Users can exercise their rights concerning their Data.

Processors: We use the services of third party providers, who process your Personal Data as data processors on our behalf. They provide us with services related to the support of certain features of the Service (webinars), hosting, customer service, monitoring and response to security incidents, diagnosis and resolution of problems with the Service or the Platform , the display of web push notifications, the analysis of the effectiveness of marketing campaigns, as well as the analysis of the use of the Service and the Platform.

Other controllers: We collaborate with service providers who do not act exclusively at our request and who themselves determine how they treat personal data, to carry out remarketing campaigns and statistical analysis.

YOUR RIGHTS. YOU HAVE CONTROL OVER YOUR DATA.

We make sure that our Clients and Users can exercise their rights over their Data.

You may exercise your rights by filing a demand to the following Emails address: info@bottleneckcorp.com. All you need to do is to inform us about the reason for your motion and the right you want to exercise. If you have an account in the Service, you can exercise some of your rights directly after you log in to your account. Please remember that if you change your settings in the Account, we may need up to 3 hours to apply the changes in our systems due to technical reasons. That’s why during this time you may still receive an Emails message from our system while it’s updating your settings.

If we decide it’s necessary, we may ask you some additional questions or ask you to provide us with additional documents to confirm your identity.

It may sound obvious, but for the sake of clarity, we would still like to point out that exercising your rights described below is free of charge, with the possible exception of providing additional copies of your Data.

 Right to express and withdraw your consent:

If we ask for your consent for the processing of your Data, you can always choose to give it or not. We inform you about the right to withdraw your consent before giving it. In our Platform, we never request the same consent for different personal data processing operations, and we never depend on consent to execute the contract -including the provision of the Service- even if the consent is not necessary for its execution.

Additionally, you are entitled to withdraw any consent previously given at the point of creating an Account or using the Platform and Services, including:

Processing your Emails address to send you our marketing communication to your Emails address,

Collect your data by cookies.

Withdrawal of your consent is effective upon execution, and it does not affect the lawfulness of processing based on the consent before you withdraw it. You can always withdraw your consent without detriment. It may, however, render you unable to use some of the features of the Platform or the Services which we may legally render only with your consent (e.g., receiving the newsletter on the new updates in our Resources).

You may withdraw your consent in one of the following ways:

By clicking “unsubscribe” in the Emails you received,

If you agree to the use of cookies – in your browser settings,

As described in section our contact details.

We treat withdrawing your consent to receive marketing communication as objecting to profiling for marketing purposes.

Right of access

You have the right to obtain confirmation if we process your Personal Data. If we do, you have the right to:

Receive information on the rules of such processing,

Access your Personal Data,

Receive a copy of your Data.

If you have an account with the Service, you can directly access the personal data you provided at all times, after logging into your Account.

The first copy of your Data is free of charge. For any further copies you request, we may charge you a reasonable fee based on the administrative costs resulting from preparing this information.

Right to rectification

You have the right to rectify and complete the Personal Data you provide. You can do it yourself in your Account. Concerning other personal data, you have the right to have us rectify inaccurate personal data concerning you or complete your incomplete personal data.

Right to erasure (“right to be forgotten”)

On the grounds described by the law, you have the right to have us erase your Personal Data. We’ll treat your demand to erase all your Personal Data as a demand to delete your Account.

You have the right to have us erase your Personal Data if:

The Personal Data has been unlawfully processed or has to be erased to comply with a legal obligation;

Your Personal Data is no longer necessary about the purposes for which it was collected or otherwise processed;

You have withdrawn consent to the processing of your Data (and when there are no other legal grounds for processing);

You have objected to the processing of your Data for marketing-related purposes;

You have objected to the processing of your Data for statistical purposes of using the Platform or the Service and surveying customer satisfaction, and the objection has been considered legitimate.

We will keep some of your Data despite the demand to erase it if it’s necessary for performing our legal duties or establishing, pursuing, or defending a claim. It especially refers to Personal Data concerning your name, surname, Emails address, and the Platform or Service use history, which we keep to be able to address complaints and claims connected to the Platform or use of the Service.

Right to restriction of processing

If you file such a demand, we will make some of the features of the Platform or Service connected to the processing of the Data covered by your demand unavailable to you while we review it. During that time, we will not send you any communication including marketing communication.

You have the right to have us restrict the processing of your Data when one of the following applies:

You contest the accuracy of your Data;

The processing of your Data is unlawful, and you request the restriction of its use instead of erasing it;

We no longer need your Personal Data to process it, but you require it to establish, exercise, or defend legal claims;

You object to the processing of your Data.

Right to object

You have the right to object, on grounds relating to your specific situation, at any time, to the processing of your Data, providing that we are processing your Data based on our legitimate interests.

These cases are pointed out in the sections regarding the processing for legitimate interests and marketing purposes, including creating your profile.

In particular, you have the right to object to the processing of your Data for direct marketing purposes, including profiling. In such a case, we will no longer process your Data for these purposes, and you will no longer receive any marketing information from us. Additionally, we’ll treat the withdrawal of the consent to receive marketing communication about our products or services as an objection to the processing of your Data for direct marketing purposes, including profiling.

Regarding the processing for legitimate interests as pointed out above, if your objection turns out to be legitimate and we don’t have any other legal grounds for processing your Data, we will remove the Data you don’t want us to process.

Right to data portability

If you set up a Customer Account or you consented to the processing of your Data, you have the right to receive the Personal Data you provided to us and transmit it to another controller in a structured, commonly used, machine-readable format. We will send your Personal Data in CSV format. This format is commonly used and machine-readable and enables the transmission of your Data to another data controller.

If you are our Customer you may exercise your right after logging in to your account.

Other useful information

Do I have to provide BOTTLENECK CART with my Personal Data?

Sometimes we ask you to provide us with your Personal Data. Providing:

Registration data

Data provided as Account details, and

Other data (indicated as mandatory) in registration forms is essential for us to create your Account, send you the requested materials or enable you to participate in a chosen event. If you don’t provide us with the relevant data, you will not be able to use some or all features of the Platform or Service. Providing us with data other than the mandatory data is voluntary.

HOW LONG DO WE STORE YOUR PERSONAL DATA?

If you are our Customer, we store your Personal Data for the time during which you have an account with our Service. When you deactivate your Account, we’ll store your Data for 60 days for the sole purpose of enabling you to reactivate the Account. During that time, we’ll only store your data without any other processing activities subject to our other obligations or rights arising from applicable laws or public authority orders. After that time, we’ll delete your data from the main database, without the possibility to recover it. In the next 120 days, your Personal Data will be subject to encryption and stored in backup copies only. The said 120-day period is required to delete the Personal Data completely due to the specifics of the backup copy operations.

We’ll store the Personal Data of the Users who are not our Customers for the time corresponding to the lifecycles of the cookie files saved on their devices. You will find the details of how we use cookies in our Cookie Policy.

We’ll store the Personal Data of our newsletter subscribers or persons who have agreed to receive marketing content from us until they resign.

After expiration of the periods described above, your Data will be erased, excluding the following data:

Name,

Surname,

Emails address,

Service usage history, and information about expressed consents.

We’ll store this data only for as long as we need to handle complaints and manage claims related to the use of the Service, and for as long as is required by tax and accounting regulations.

HOW DOES BOTTLENECK CART PROTECT MY PERSONAL DATA?

We implemented adequate and effective measures to ensure the security of your personal data. The Platform uses encrypted data transmission (SSL, secure socket layer) during registration and login, which guarantees the protection of the data identifying you and significantly impedes account data interception by unauthorized systems or people.

UPDATING OUR PRIVACY POLICY

We may change this Privacy Policy at any time. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your Account. If we make changes to this Privacy Policy, we will notify you by publishing information here before the changes take effect.

If, however, we make material changes to this Policy, we may also send you a separate notification to the Email address you provided us with.

The Privacy Policy does not restrict any of your rights under the Terms of Service or applicable provisions of the law.