Privacy Policy

PRIVACY NOTICE

Last Updated: May 2, 2021

TABLE OF CONTENTS

WHAT INFORMATION DO WE COLLECT?
HOW DO WE USE YOUR INFORMATION?
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
CHILDREN’S PRIVACY
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Thank you for choosing to be part of our community at MyBT LLC. (“Company”, “we”, “us”, “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at support@mybehaviortech.com.

When you visit our website http://www.mybehaviortech.com (the “Website”), use our mobile application, as the case may be (the “App”) and more generally, use any of our services (the “Services”, which include the Website and App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In the privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our Website and App), as well as, any related services, sales, marketing, or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

WHAT INFORMATION DO WE COLLECT?

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect email addresses; usernames; passwords; approximate user age; and other similar information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link here: http://stripe.com/prviacy-center/legal.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at support@mybehaviortech.com and be sure to include your name, testimonial location, and contact information.
Request feedback. We may use your information to request feedback and to contact you about your use of our Services.
To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
To send administrative information to you. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To send you marketing and promotional communications. We and/or third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see “WHAT ARE YOUR PRIVACY RIGHTS?” below).
Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than three (3) months past the start of idle period of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds than consent.

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.edu/justice/data-protection/bodies/authorities/index_en.htm

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html

If you have questions or comments about your privacy rights, you may email us at support@mybehaviortech.com.

Account Information:

If you would at any time like to review or change the information in your account or terminate your account, you can:

Log in to your account settings and update your user account
Email your request to support@mybehaviortech.com

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opting out of email marketing:

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list- however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may access your account settings and update your preferences.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a DO-NOT-TRACK (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

DO CALIFORNIA RESIDENTS HAVE SPECFIIC PRIVACY RIGHTS?

In Short: Yes, you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we ahead personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice:

The California Code of Regulations defines a “resident” as:

Every individual who is in the State of California for other than a temporary or transitory purpose and
Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name	Yes
B. Personal information categories listed in the California Customer Records statute	Name, contact information, education, employment, employment history and financial information.	Yes
C. Protected classification characteristics under California or federal law	Gender and date of birth	Yes
D. Commercial information	Transaction information, purchase history, financial details and payment information	No
E. Biometric information	Fingerprints and voiceprints	No
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, and systems and advertisements	No
G. Geolocation data	Device location	No
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	Yes
I. Professional or employment-related information	Business contact details in order to provide you our services at a business level, job title, as well as work history and professional qualifications if you apply for a job with us	No
J. Education information	Student records and directory information	No
K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.	No

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us y email at support@mybehaviortech.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

MyBT LLC. has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. MyBT LLC. will not sell personal information in the future belonging to website visitors, users and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data- Request to delete:

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or ay processing that may be required to protect against illegal activities.

Right to be informed- Request to know:

Depending on the circumstances, you have a right to know:

Whether we collect and use your personal information;
The categories of personal information that we collect;
The purposes for which the collected personal information is used;
Whether we sell your personal information to third parties;
The categories of personal information that we sold or disclosed for a business purpose;
The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
The business or commercial purpose for collecting or selling personal information

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights:

We will not discriminate against you if you exercise your privacy rights.

Verification process:

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for the security of fraud prevention purposes. We will delete such additionally provided information as soon as finish verifying you.

Other privacy rights:

You may object to the processing of your personal data
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an unauthorized

To exercise these rights, you can contact us by email at support@mybehaviortech.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

CHILDREN’S PRIVACY

MyBT LLC. is committed to protecting the privacy of children who use our sites and applications. This Children’s Privacy Policy explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13 (“child” or “children”). This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online at https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online .

MyBT App is primarily targeted for use by children, and their families. Our App offers educational instruction including activities that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

Information Collected from Children Under the Age of 13

The Company may collect and store persistent identifiers such as cookies or IP addresses from Children without parental consent for the purpose of supporting the internal operation of the Service.

We may collect and store other personal information about children if this information is submitted by a child with prior parent consent or by the parent or guardian of the child.

The Company may collect and store the following types of personal information about a child when submitted by a child with prior parental consent or by the parent or guardian of the child:

First name or “Nickname”
Month and Year of birth
Parent’s or guardian’s name
Parent’s or guardian’s email address

For further details on the information We might collect, You can refer to the “Types of Data Collected” section of this Privacy Policy. We follow our standard Privacy Policy for the disclosure of personal information collected from and about children.

Registration

Children under the age of 13 are not permitted to register with our sites and applications. Children under the age of 13 are permitted to use the App through their parent’s or guardian’s registered account.

If you discover that your child or another child under the age of 13 is using our site or App without parental consent or the consent of a guardian, please notify us immediately, by emailing support@mybehaviortech.com.

During the registration process, we may ask the child’s parent or guardian to provide certain information for notification and security purposes, including a parent or guardian’s email address, a child’s first name or “nickname,” the account username, and password. We also ask for month and year of birth of primary users (i.e. children) to aggregate anonymized data with respect to user performance and age. Providing a month and year of birth may be declined using an on-screen option. We strongly advise parents never provide any personal information in their usernames. Please note that family or children can choose whether to share their information with us, but certain features cannot function without it. As a result, family or children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in using Services.

About the collection of parent email address: Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at support@mybehaviortech.com. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.

About Verifiable Parental Consent:

Email Consent. In the event MyBT LLC. wishes to collect personal information from a child, COPPA requires that we first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.

High-Level Consent. In the event MyBT LLC. collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to verification, speaking to a trained customer service representative by telephone, or requiring a signed consent form by mail, email attachment, or fax. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent’s identity.

Teacher consent in lieu of a parent. With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.

Chat

Our games and activities directed to children DO NOT allow users to communicate directly with other users by means of a chat system. We also recommend that parents carefully supervise their children when the children participate in online activities.

Email Contact with a Child

MyBT App does NOT collect the email address of the child. MyBT LLC. will not make attempts to communicate with the child via email or by any other means such as telephone, or mail. All correspondence, consent methods, and other forms of communication will be conducted through parent’s or guardians using the parent email address provided during registration.

Geolocation Data

MyBT App does NOT collect geolocation information that is specific enough to equate to the collection of a street address. Geolocation data will be collected to inform the Company about user data with regard to country from which the App is accessed, and will only be used to ensure continued functioning of our Services and for internal business purposes. Parents may opt-out of geolocation data collection through their device during the registration process.

When Information Collected From Children Is Available To Others

In addition to those rare instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following:

We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.

We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

Parental Access

A parent who has already given the Company permission to collect and use his child personal information can, at any time:

Review, correct or delete the child’s personal information
Discontinue further collection or use of the child’s personal information

To make such a request, You can contact Us via email at support@mybehaviortech.com. A valid request to delete personal information will be accommodated within a reasonable time period, no longer than 30 days.

DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@mybehaviortech.com or by post to:

MyBT LLC.

55 Pepperidge Circle

Stratford, CT 06614

United States

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information please submit a request via email at support@mybehaviortech.com.