Privacy Policy

EFFECTIVE DATE - October 1, 2021

1. Introduction

1.1 btw (“us”, “we”, or “our”) operates the website and the btw mobile application (collectively, the “Services”). This page informs you of our policies and practices regarding the collection, use, and disclosure of information that personally identifies you (“Personal Information”) when you use our Services. We will not use or share your information with anyone except as described in this privacy policy. We use your Personal Information for providing and improving the Services. By using the Services, you agree to the collection and use of your Personal Information in accordance with this Privacy Policy.

1.2 When we refer to btw, we mean Adaface Pte Ltd, a company registered in Singapore with a registered address at 32 Carpenter Street, Singapore;

1.3 This Privacy Policy applies to all engagements with the following Sites and Services:

1.4 This Privacy Policy applies to you if you:

  • interact with btw's sites ("website users")
  • use btw's product-led growth services for your business ("customers")
  • interact with btw's sites and services on our customer domains ("end-users")

1.5 For the purposes of the General Data Protection Regulation (or any successor or equivalent legislation in the UK) ("GDPR"), btw is the controller of your personal data.

2. What information does btw collect/receive

2.1 Here's the list of data we collect about you when you engage with btw's sites and services-

  • Email addresses (provided by customers, website visitors and end-users)
  • Name, Phone Number (provided by the customers, website visitors and end-users)
  • Company name and role in the company (provided by customers to create an account to use btw Services)
  • Avatars (automatically deduced using Gravatar or overridden by customers using btw Services)
  • Credit card information and related payment information (provided by customers to use btw paid Services)
  • Device data like OS, Browser type, IP address, unique device identifier (automatically captured when customers, end-users and website visitors engage with the Sites or Services)
  • Service data like referrer data, engagement data on btw Sites and btw customer domains (automatically captured when customers, end-users and website visitors engage with btw Sites, Services or btw customers domains)

2.2 Cookie usage

Some device data, service data and third party source data is collected through the use of first or third party cookies and similar technologies. We do not collect, retain, or share data regarding a particular user's activity across multiple websites or applications that are not owned by btw or our customers. btw does assign each user a unique user ID within the scope of an individual website, but does not collect or retain IP or any information that would allow btw to identify the same particular user on more than one website.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

2.3 Children's privacy

If you're a child under the age of 13, you may not have an account on the btw Sites and Services. btw does not knowingly collect information from or direct any of our Website or content specifically to children under 13. If we learn or have reason to suspect that a user is under the age of 13, we will close the child’s account.

Other countries may have different minimum age limits. If you are below the minimum age for providing consent for data collection in your country, you may not use btw.

3. How and why does btw use/process your information

3.1 We collect and process your personal data for the following purposes and, if you are from the European Economic Area (EEA), the UK or Switzerland, on the following legal bases:

3.2 We process your personal data to perform our contract with you for use of our Services and Sites and to fulfill our obligations under applicable terms of service.

3.3 We may send you service, technical and other administrative messages in reliance on our legitimate interests in administering the btw Services. We process your personal data to provide customer care and support while using btw Sites and Services as website visitors or users. We also process your personal data to enable btw's customers provide customer care and support on domains where btw Services are enabled.

3.4 We process your personal data to improve and optimize the btw Services and Sites and btw customers Sites and Services where btw Services are enabled. This includes monitoring usage or traffic patterns, analyzing trends and developing new products, services, features and functionality in reliance on our legitimate interests.

3.5 We process your personal data to send you marketing communications via email or SMS about our products, services and upcoming events that might interest you in reliance on our legitimate interests or where we seek your consent. You can control your marketing preferences and choose to withdraw your consent at any time through the unsubscribe feature provided with each marketing email or by contacting us at [email protected]

3.6 We process your personal data to control unauthorized use or abuse of the btw Services and Sites, or otherwise detect, investigate or prevent activities that may violate btw policies or applicable laws, in reliance on our legitimate interests to maintain and promote the safety and security of the btw Sites and Services.

3.7 Carrying out other legitimate business purposes including invoicing, audits, fraud monitoring and prevention. We process your personal data when cooperating or complying with public and government authorities, courts or regulators in accordance with our obligations under applicable laws and to protect against imminent harm to our rights, property or safety, or that of our users or the public, as required or permitted by law.

4. How does btw share your data

4.1 btw will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors, and affiliated organizations, btw discloses potentially personally-identifying and personally-identifying information only when required to do so by law, or when btw believes in good faith that disclosure is reasonably necessary to protect the property or rights of btw, third parties, or the public at large.

4.2 btw takes measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information.

4.3 btw at its sole discretion may make use of company logos where those companies are using the software that we provide. If you have concerns over the use of your logo, please email [email protected]

4.4 btw may also share aggregated or anonymized information with third parties for other purposes. Such information does not identify you individually, but may include usage, viewing and technical information such as the websites you generally use, the configuration of your computer, and performance metrics related to the use of websites which we collect through our technology, products and services.

4.5 btw Sites may also contain links to third party websites. This Privacy Policy applies solely to information processed by us. You should contact the relevant third party websites for more information about how your personal data is processed by them.

5. How does btw retain and share your data

5.1 We retain your personal data only for as long as necessary to fulfill the purposes set out in this Privacy Policy.

5.2 Note that content you post may remain on the Sites even if you cease using the Sites or we terminate access to the Sites.

5.3 btw Sites are hosted in the United States and information we collect will be stored and processed on our servers in the United States. Our employees, contractors and affiliated organizations that process information for us as described above may be located in the United States or in other countries outside of your home country; by using the Website, you consent to the international transfer of your information by btw. btw will protect your personal data in accordance with this Privacy Policy wherever it is processed.

5.4 Depending on the btw Service you opt for, certain recipients (our service providers and other companies) who process your personal data on our behalf may also transfer personal data outside the country in which you are resident. Where such transfers occur, we will make sure that an appropriate transfer agreement is put in place to protect your personal data.

5.5 You are entitled to the following with regard to your personal information and data:

  • If you wish to access, correct, update or request deletion of your personal data, you can do so at any time
  • You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data.

To exercise your privacy rights, you can email us at [email protected]

6. Contacting btw

6.1 You can contact us using our customer support services on btw Sites or write to us at [email protected] regarding any questions or concerns about your data. Please note, we will need to verify your identity to process your information, access, and deletion requests. Note that, in some instances, we may decline your request as permitted by law.

7. Privacy Policy changes

7.1 Although most changes are likely to be minor, btw may change its privacy policy from time to time, and in btw's sole discretion. We may also provide notification to users who have provided us email addresses of material changes to this Privacy Policy through our Website. btw encourages visitors to frequently check this page for any minor changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

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