Legal

Introduction & Scope

This Acceptable Use Policy (“AUP”) applies to any user (a “User”) of BBH Solutions, Inc. (“BBH”) Internet services and corresponding network, equipment, and facilities (collectively, the “Services”), regardless of whether the User obtains access to the Services directly from BBH or through a third party, and regardless of whether the User resells or otherwise provides the Services to a third party. All Users are required to comply with this AUP.

Users purchasing Services from BBH (“Customers”) are responsible for any third-party Users’ compliance with the terms of this AUP, and must take all necessary steps to such ensure compliance.

By using the Services, Users agree to comply with this AUP and to remain responsible for any other Users to whom they provide access to the Services. BBH reserves the right to change or modify the terms of the AUP at any time, with those changes or modifications effective when posted on BBH’s website at www.bbhinc.com. A User’s use of the Services after changes to the AUP are posted shall constitute acceptance of any changed or additional terms.

Prohibited Activities

BBH prohibits the use of the Services in anyway that is unlawful, harmful, or that interferes with the Services or that is harmful or interferes with the services, network, equipment, or facilities of any other provider.  BBH also prohibits any activities by a User that interferes with the use or enjoyment of the Services received by others, infringes intellectual property rights, results in the publication of threatening or offensive material, or constitutes Spam/E-mail/Usenet abuse, a security risk or a violation of privacy. A non-exhaustive list of prohibited activities includes:

  • Fraudulent Use of the Services.  Users may not seek to circumvent or alter the process or procedures to measure time, bandwidth utilization, or other methods used to document “use” of the Services or any other BBH services.
  • Other Activities. The Services may not be used to engage in activities, whether lawful or unlawful, that BBH determines to be harmful to its Customers, Users, operations, reputation, or goodwill. Violating any specific instructions given by BBH (i) to ensure the safety or quality of the Services or any other services provided by BBH or (ii) to ensure the compatibility of equipment attached to the Services is prohibited.
  • Unlawful Activities: The Services shall not be used in connection with any criminal, civil or administrative violation of any applicable local, state, provincial, federal, national or international law, treaty, court order, ordinance, regulation or administrative rule.
  • Violation of Intellectual Property Rights: The Services shall not be used to publish, submit/receive upload/download, post, use, copy or otherwise reproduce, transmit, re-transmit, distribute or store any content/material or to engage in any activity that infringes, misappropriates or otherwise violates the intellectual property rights or privacy or publicity rights of BBH or any individual, group or entity, including but not limited to any rights protected by any copyright, patent, trademark laws, trade secret, trade dress, right of privacy, right of publicity, moral rights or other intellectual property right now known or later recognized by statute, judicial decision or regulation.
  • Threatening Material or Content: The Services shall not be used to host, post, transmit, or re-transmit any content or material (or to create a domain name or operate from a domain name), that harasses, or threatens the health or safety of others.
  • Inappropriate Interaction with Minors: The Services shall not be used to engage in inappropriate interaction with minors. BBH complies with all applicable laws pertaining to the protection of minors, including when appropriate, reporting cases of child exploitation to the National Center for Missing and Exploited Children. For more information about online safety, visit www.ncmec.org.
  • Forging of Headers or Content.  The Services shall not be used to forge, alter, misrepresent, or removing message headers, whether in whole or in part, to mask the originator of the message and forging, falsifying, altering, misrepresenting or removing any data is prohibited.
  • Distribution of Internet Viruses, Worms, Trojan Horses, or Other Destructive Activities.  The Services may not be used, knowingly or unknowingly, to send Internet viruses, worms, Trojan horses, flooding, mail bombing, or denial of service attacks, or to distribute information regarding the creation of such viruses, worms, etc. for reasons other than mitigation or prevention.
  • Spam/E-mail/Usenet Abuse: Use of the service to violate of the CAN-SPAM Act of 2003, or any other applicable law regulating e-mail services, constitutes a violation of this AUP. Examples of Spam/E-mail or Usenet abuse include, but are not limited to, the following activities:
    • sending multiple unsolicited electronic mail messages to one or more recipient;
    • sending unsolicited commercial e-mail, or unsolicited electronic messages directed primarily at the advertising or promotion of products or services;
    • sending bulk electronic messages without identifying and implementing, within the message, a reasonable means of opting out from receiving additional messages from the sender;
    • sending electronic messages, files or other transmissions that exceed contracted for capacity or that create the potential for disruption of the Services or of the networks with which BBH interconnects;
    • using another computer, without authorization, to send multiple e-mail messages or to retransmit e-mail messages;
    • collecting the responses from unsolicited electronic messages;
    • falsifying packet header, sender, or user information whether in whole or in part to mask the identity of the sender, originator or point of origin;
    • using redirect links in unsolicited commercial e-mail to advertise a website or service;
    • posting a message to multiple online forums or newsgroups, that could reasonably be expected to generate complaints;
    • intercepting, redirecting or otherwise interfering or attempting to interfere with e-mail intended for third parties;
    • knowingly deleting any author attributions, legal notices or proprietary designations or labels in a file that the user mails or sends;
    • using, distributing, advertising, transmitting, or otherwise making available any software program, product, or service that is designed to violate this AUP or the AUP of any other Internet Service Provider, including, but not limited to, the facilitation of the means to spam.
Fraudulent Use of the Services.  Users may not seek to circumvent or alter the process or procedures to measure time, bandwidth utilization, or other methods used to document “use” of the Services or any other BBH services.

Other Activities. The Services may not be used to engage in activities, whether lawful or unlawful, that BBH determines to be harmful to its Customers, Users, operations, reputation, or goodwill. Violating any specific instructions given by BBH (i) to ensure the safety or quality of the Services or any other services provided by BBH or (ii) to ensure the compatibility of equipment attached to the Services is prohibited.Security ViolationsThe Services may not be used to interfere with, gain unauthorized access to, or otherwise violate the security of BBH’s (or another party’s) Services, server, network, network access, personal computer or control devices, software or data, or other system, or to attempt to do any of the foregoing. Examples of system or network security violations include but are not limited to:

  • unauthorized monitoring, scanning or probing of network or system or any other action aimed at the unauthorized interception of data or harvesting of e-mail addresses;
  • hacking, attacking, gaining access to, breaching, circumventing or testing the vulnerability of the user authentication or security of any host, network, server, personal computer, network access and control devices, software or data without express authorization of the owner of the system or network;
  • impersonating others or secretly or deceptively obtaining personal information of third parties (phishing, etc.);
  • using any program, file, script, command or transmission of any message or content of any kind, designed to interfere with a terminal session, the access to or use of the Internet or any other means of communication;
  • distributing or using tools designed to compromise security (including but not limited to SNMP tools), including cracking tools, password guessing programs, packet sniffers or network probing tools (except in the case of authorized legitimate network security operations);
  • knowingly uploading or distributing files that contain viruses, spyware, Trojan horses, worms, time bombs, cancel bots, corrupted files, root kits or any other similar software or programs that may damage the operation of another’s computer, network system or other property, or be used to engage in modem or system hi-jacking;
  • engaging in the transmission of pirated software;
  • using manual or automated means to avoid any use limitations placed on the Services;
  • providing guidance, information or assistance with respect to causing damage or security breach to BBH’s network or systems, or to the network of any other IP Service provider;
  • failure to take reasonable security precautions to help prevent violation(s) of this AUP.

Customer Responsibilities

Customers are responsible for ensuring that any Users to whom they provide access to the Services comply with the terms of this AUP. Failure to ensure that Users comply with the AUP may result in the loss of access to the Services for Customer in addition to the User. To the extent that a violation of this AUP occurs, Customers are responsible for taking prompt corrective action(s) to remedy a violation of AUP and to prevent similar future violations.

Incident & Abuse Reporting

Any complaints (other than a claim of copyright infringement) regarding violation of this AUP by a User should be directed to legal@bbhinc.com.  Where possible, please include details that will assist BBH in investigating and resolving such complaint (e.g., expanded headers, IP address(s), a copy of the offending transmission and any log files).

BBH will respond expeditiously to process and investigate notices of alleged infringement and will take appropriate actions in accordance with the Digital Millennium Copyright Act (“DMCA”) and other applicable intellectual property laws.

Upon receipt of notices complying or substantially complying with the DMCA, when it is under its control, BBH will remove or disable access to any material claimed to be infringing or claimed to be the subject of infringing activity and will remove or disable access to any reference or link to material or activity that is claimed to be infringing. Copyright holders believing that a copyrighted work has been copied and is accessible through the Services in a manner that constitutes copyright infringement may notify us by providing our designated agent with the information required by Section 512(c)(3) of the DMCA (17 U.S.C. § 512). Notices of claimed infringement should be directed to:

BBH Solutions, Inc.
Attn: Legal
121 East 24th Street – 6th Floor
New York, NY 10010

When BBH disables access to any material claimed to be infringing, BBH may attempt to contact the User who has posted such material in order to give that User an opportunity to respond to the notification.  Users receiving such a notification of alleged infringement as described above who believe in good faith that the allegedly infringing works have been removed or blocked by mistake or misidentification, may send a counter notification to BBH. Any and all counter notifications submitted by a User (to the address set forth immediately above) will be furnished to the complaining party. BBH will give the complaining party an opportunity to seek judicial relief in accordance with the DMCA before BBH replaces or restores access to any material as a result of any counter notification.

Any Customer permitting Users to obtain access to the Services through services offered by that Customer must adopt and implement a copyright infringement policy that reserves the necessary rights to remove or disable access to infringing material made available by those Users to whom it provides access.

AUP Enforcement and Notice

In the event a User fails to comply with the policies set forth in this AUP, BBH has sole discretion to remedy the violation as it deems fit, with such remedies ranging from a warning to the User to the complete termination of User’s access to the Services.

In the event a Customer fails to prevent violations of this AUP by Users obtaining access to the Services through that Customer, BBH has sole discretion to remedy the violation as it deems fit, with such remedies ranging from a warning to the complete termination of the Customer’s access to the Services.

BBH shall not be required to make a final determination of the validity of complaints received or of information obtained before taking action under this AUP. BBH further reserves the right to act immediately and without notice to suspend or terminate affected Services in response to a court order or government notice that certain conduct must be stopped or when BBH reasonably determines, that the conduct may: (1) expose BBH to sanctions, prosecution, civil action or any other liability, (2) cause harm to or interfere with the integrity or normal operations of the Services, BBH’s network, or networks with which BBH is interconnected, (3) interfere with another User’s use of the Services, (4) violate any applicable law, rule or regulation, or (5) otherwise present an imminent risk of harm to the Services, BBH, or Users.

BBH has no obligation to monitor content of any materials distributed or accessed using the Services. However, BBH may monitor content of any such materials as necessary to comply with applicable laws, regulations or other governmental or judicial requests; ensure compliance with this AUP; or to protect the Services and its Users.


E911 Disclosures for Business Voice Over IP (VoIP) Service

Service Distinctions

Emergency 911 service for telephones connected to BBH’s VoIP service (“VoIP Phones”) is different than traditional 911 services.

Unlike traditional 911 services, the Enhanced 911 (E911) service available through VoIP Phones has the ability to deliver the name, telephone number and address associated with the VoIP Phone to the local emergency response center assigned to that address. These local emergency response centers are also called Public Service Answering Points (PSAPs). Dispatchers at the local PSAP will then dispatch emergency crews to the address associated with that VoIP Phone from which the call originated.

The address associated with the VoIP Phone (and therefore the one used to route the call to the appropriate PSAP) is the physical address registered with BBH for the VoIP Phone (the “Registered Address”). Since the Registered Address for the VoIP Phone is the one used by dispatchers at the PSAP to dispatch emergency crews, you must be sure to register the primary physical address where each VoIP Phone will be used, and to immediately update the Registered Address for a VoIP Phone any time the VoIP Phone is relocated to a new address.

IF A CUSTOMER DOES NOT REGISTER ACCURATE AND UP-TO-DATE ADDRESS INFORMATION FOR A VOIP PHONE, E911 CALLS FROM THAT PHONE WILL BE ROUTED TO AN INCORRECT PSAP AND/OR EMERGENCY CREWS WILL BE DISPATCHED TO AN INCORRECT ADDRESS.

Anyone who dials 911 using a VoIP Phone should immediately tell the dispatcher his or her location (or the location of the emergency, if different) and callback number. Callers should not disconnect the line, in case the dispatcher misplaces or incorrectly records the callback number. If the caller is unable to speak and describe his or her location, the emergency dispatcher may not be able to locate the his or her precise location.

Service Limitations

The E911 services have certain limitations of which customers should be aware.

In certain instances, (1) A CUSTOMER’S E911 CALLS MAY BE ROUTED TO AN INCORRECT PSAP AND/OR EMERGENCY CREWS MAY BE DISPATCHED TO AN INCORRECT ADDRESS (IN WHICH CASE, THE DISPATCHER MAY BE UNABLE TO TRANSFER THE CALL TO THE CORRECT PSAP), (2) CALLS PLACED TO 911 FROM MAY BE SENT TO THE NATIONAL EMERGENCY CALL CENTER (RATHER THAN A LOCAL PSAP), WHERE THE CALLER WILL NEED TO PROVIDE HIS/HER NAME, TELEPHONE NUMBER AND LOCATION, BEFORE THE LOCAL EMERGENCY CENTER CAN BE CONTACTED TO SEND HELP, OR (3) A CUSTOMER MAY NOT HAVE ACCESS TO E911 SERVICE.

For example:

A CUSTOMER’S E911 CALLS WILL BE ROUTED TO AN INCORRECT LOCAL EMERGENCY SERVICE PROVIDER AND/OR EMERGENCY CREWS WILL BE DISPATCHED TO AN INCORRECT ADDRESS

  1. when the customer does not register accurate address information;
  2. when the customer moves a VoIP Phone to a new physical address without updating the Registered Address for that phone; and
  3. for up to four (4) days following the submission of a new Registered Address when a new address is registered or a previously registered address is updated, due to delays in the process of updating the Registered Address database.

CALLS PLACED TO 911 FROM WILL BE SENT TO THE NATIONAL EMERGENCY CALL CENTER RATHER THAN A LOCAL PSAP

  1. when a customer fails to register an address for a VoIP Phone;
  2. when there are no local PSAPs in the area of the Registered Address; or
  3. when a customer changes a phone number or adds or ports a new phone number to its account without registering the location of use for the changed, added or ported phone number.

A CUSTOMER WILL NOT HAVE ACCESS TO E911 SERVICES

  1. when there is an interruption of the customer’s broadband, high-speed internet access service or other data transport service;
  2. when the equipment on the customer’s premises or in BBH’s locations (including, offices or data centers) fails for any reason including, but not limited to hardware or software failures or misconfiguration either by BBH, the customer and/or any vendors;
  3. in the event of a power outage;
  4. in connection with out-dialing systems, including home security systems and medical monitoring equipment;
  5. if the customer moves its VoIP Phone outside of the United States;
  6. when there is network congestion and/or reduced routing speed (whether on BBH’s network or another network) that causes (a) busy signals, (b) unexpected answering wait times (which may be longer than 911 calls placed via traditional telephone networks), or (c) failure of the call;
  7. due to spikes in call volume, such as, in the wake of local or national disasters; and
  8. when the customer’s service has been cancelled or terminated, whether by the customer or by BBH.

Required Notification and Warnings

CUSTOMERS MUST INFORM ALL POTENTIAL USERS WHO MAY BE PRESENT AT THE PHYSICAL LOCATION WHERE BBH’S VOIP SERVICE IS USED OF THE IMPORTANT DIFFERENCES IN AND LIMITATIONS OF BBH’S VOIP E911 SERVICE AS COMPARED WITH BASIC 911 OR E911 PROVIDED BY TRADITIONAL LANDLINE TELEPHONE SERVICE.

BBH WILL PROVIDE CUSTOMERS WITH NOTIFICATION MATERIALS AND WARNING LABELS REGARDING THE LIMITATIONS OR UNAVAILABILITY OF 911 EMERGENCY DIALING, WHICH LABELS CUSTOMERS MUST PLACE ON EACH VOIP PHONE AND ON ANY OTHER DEVICE THAT WILL BE USED WITH BBH’S VOIP SERVICE. FOR ADDITIONAL NOTIFICATION MATERIALS AND WARNING LABELS, PLEASE CONTACT BBH’S CUSTOMER SERVICE DEPARTMENT.

Customer Acknowledgments

Customers acknowledge and agree to the following:

  1. it is the customer’s responsibility to ensure that the Registered Address is accurate and up-todate at all times;
  2. calls routed to a PSAP may not be answered by a dispatcher who is specifically trained or designated to receive incoming emergency response calls;
  3. the phone lines at the PSAP where the call is routed may be occupied, resulting in a busy signal;
  4. the local PSAP may not have a system configured for E911 services or be able to capture and/or retain automatic number or location information, in which case the operator will not know the phone number or physical location of the person making the call;
  5. in the event that an E911 call is routed to a national emergency call center, the call center may disclose the name and address provided to any and all third parties involved with providing emergency services, including, without limitation, call routers, call centers and local emergency centers;
  6. E911 calling will not function during a power outage, unless customers provides the electricity locally to power the equipment;
  7. the E911 service may not function during network congestion;
  8. the E911 service does not provide access to emergency services in any country outside of the United States, and BBH disclaims any obligation to provide Customers with access to emergency services in any jurisdiction other than the United States;
  9. a VoIP service outage due to suspension of a customer’s account (as a result of billing issues or any other reason) will prevent ALL service, including the emergency response service; and
  10. BBH’s VoIP service is not intended to be used for personal or residential purposes, so home office users must provide alternative arrangements for residential emergency calls.

CUSTOMERS ACKNOWLEDGE THAT BBH DOES NOT AND CANNOT GUARANTEE THAT THE VOIP SERVICE WILL BE CONTINUOUS OR ERROR-FREE. CUSTOMERS FURTHER ACKNOWLEDGE THAT NOT ONLY WILL THE E911 SERVICE BE UNAVAILABLE WHENEVER THE VOIP SERVICE IS
UNAVAILABLE, BUT ADDITIONAL FACTORS MAY CAUSE THE E911 SERVICE TO BE UNAVAILABLE EVEN WHEN VOIP SERVICE IS AVAILABLE.

IT IS EACH CUSTOMER’S RESPONSIBILITY TO OBTAIN ALTERNATIVE MEANS OF COMMUNICATION, SUCH AS TRADITIONAL WIRELESS OR LANDLINE TELEPHONE SERVICES FROM A THIRD PARTY, AS A BACK-UP MEANS OF PLACING CALLS, INCLUDING EMERGENCY 911 CALLS. Such alternative means should include the ability to access 911 services through the public switched telephone network (PSTN) where technically feasible.

Changes to E911 Disclosures

BBH may change these E911 Disclosures for Business Voice Over IP (VoIP) Service (“E911 Disclosures”) from time to time to align with changes to its business practices and/or legal requirements. Changes to these E911 Disclosures will be posted on this page and will be effective with respect to each customer upon its use of BBH’s VoIP service after the changes have been posted or any other indication of such customer’s consent. BBH will post a prominent notice on our website and provide customers with appropriate choices in the event that we make a material change to these E911 Disclosures. Please note that BBH may condition a customer’s continued access to our VoIP service on such customer’s execution of an acknowledgment evidencing its consent to such changes to these E911 Disclosures.


BBH Privacy Policy

The websites at http://www.BBHSolutions.com/ and www.BBHInc.com (“Website”) is owned and operated by BBH Solutions, Inc and its affiliates (“BBH”, “we” or “us”). We are committed to protecting and respecting your privacy. This Privacy Policy describes how we collect, use and share information about you that we obtain through your use of our Website and other online services provided through our Website (together, the “Services”).

This Privacy Policy applies to our Services only. While our Services may contain links to other websites, we are
not responsible or liable for the content or privacy policies of such other websites.

This Privacy Policy also does not apply to the contents that you store on our system such as, through our BConnected Data services or other services (“Customer Data”). We do not disclose, move, access or use your Customer Data, including any personal information contained in the Customer Data of you or your clients, except as provided herein or in our service or other agreement with you. Please review your agreement with us for more information about how we handle your Customer Data.

Please read this Privacy Policy carefully to understand how we will treat your information before you start to use our Services and before you start to provide us with any information about you.

BY USING OUR SERVICES OR PROVIDING ANY INFORMATION TO US THROUGH OUR SERVICES, YOU ARE ACCEPTING AND CONSENTING TO THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY, INCLUDING ANY UPDATES AND AMENDMENTS. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, YOU MUST NOT ACCESS OR USE OUR SERVICES OR PROVIDE US WITH ANY INFORMATION THROUGH OUR SERVICES

Who We Are

As used in this Privacy Policy, the terms “BBH”, “we” and “us” include BBH Solutions, Inc and its affiliates, including BBH Connectivity, Inc.

Information We May Collect From You

Information You Provide to Us

We may collect information you provide directly to us through the use of our Services, including, but not imited
to, when you register for an account, subscribe to our newsletter, purchase a product or service from us, and send any other information to us through our Services. In addition, if you send us an email, call us, fill out a feedback form, or choose to communicate with us in another way, we will collect that information in order to respond to your request, feedback, or question. We will use and share information you provide to us only as described in this Privacy Policy.

Using our Services

We collect certain technical information (“Technical Information”) to help us operate and provide our Services to you. We collect this Technical Information when you use our Services, including:

  • Information about the device(s) you use to access our Services, including MAC address, IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device type, and device identifiers;
  • Information about your visits to the Websites we provide, including the full URL clickstream to, through and from these Websites (including date and time);
  • Information we need and use to facilitate your use of our Services (including to provide access to third party websites and services), such as URL requests, destination IP addresses, or device configuration details;
  • Pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

We may supplement Technical Information we collect from you with information collected by third parties. Third parties may include advertising partners or other providers that help us understand our users and provide better service to our users.

We may collect Customer Proprietary Network Information (CPNI) in the normal course of providing you with telecommunications services and in accordance with the law. CPNI is information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service you purchased from us and information contained in our bills to you related to those telecommunications services, but excludes information such as the telephone numbers, addresses, primary advertising classifications, or a combination of these that we maintain for publication.

Personally Identifiable Information

Some of the information we collect through your use of our Services or communications with us, such as your name, work address, phone number, email address, billing information associated with your account, and the name of your employer may personally identify you. We will treat this information as “Personally Identifiable Information.” We will also treat as Personally Identifiable Information any non-identifiable information that is combined with Personally Identifiable Information.

Aggregate or Anonymized Information

We may combine Technical Information or non-Personally Identifiable Information about your use of our Services with similar information we obtain from other users for use in an aggregate or anonymous manner.

Other Collection of Information

Our Services may also, from time to time, contain links to and from social media platforms such as LinkedIn. You may choose to connect to us through a social media platform and when you do, we may collect additional Personally Identifiable Information from you, such as your screen names, profile picture, contact information, contact list, and the profile pictures of your contacts, through the social media platform. Please be advised that social media platforms may also collect Personally Identifiable Information from you. We do not have control over the collection, use and sharing practices of social media platforms and encourage you to review their usage and disclosure policies and practices, including the data security practices, before using the social media platforms.

Third parties may also collect information about you, including tracking your browsing history, when you use our
Services. We do not have control over these third party collection practices and advises you to adjust the setting of your browsers or install plug-ins and add-ins to minimize these third party collection.

We will not ask for or request sensitive information such as government identifiers, medical information, or financial information (other than for payment for our Services). Please do not provide this information to us through emails, feedback forms or in any other way.

How Your Information May Be Used

We may use any information we collect to:

  • Allow us to operate our Services, including administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • Manage your access to our Services;
  • Send you information that allows you to use our Services;
  • Comply with laws and regulations;
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including billing and collection;
  • Notify you about changes to our Services;
  • Allow you to participate in interactive features through our Services;
  • Maintain the security of our Services;
  • In any other way we may describe when you provide the information;
  • For any other purpose with your consent.

We may use your information, including Personally Identifiable Information, to:

  • Provide you with information about goods or services that may interest you;
  • Send you emails about updates, information, or alerts regarding our Services.

We may use Technical Information or non-Personally Identifiable Information to:

  • Improve our Services and present content in the best way for you and for your device(s);
  • Serve advertisements on through our Services;
  • Measure or understand the effectiveness of advertising we serve to you and other customers like you, and to deliver relevant advertising to you and other customers like you.

How Your Information May Be Shared

We will not sell your Personally Identifiable Information or share your Personally Identifiable Information with third parties for the third party’s own direct marketing purposes. Please note that if you click on or otherwise interact with an advertisement through our Services, however, the advertiser may assume that you meet its target criteria, even though we have not shared your Personally Identifiable Information.

We may share information, including Personally Identifiable Information, with our service providers and agents to the extent reasonably necessary to provide you with our Services. For example, we use a third party platform for
email and cannot communicate with you without disclosing your email address to our third party email provider. These third parties use any information we share only to support us and our efforts to provide our Services.

We may share any information, including Personally Identifiable Information with:

  • Our subsidiaries and affiliates
  • Our service providers and sub-contractors to the extent reasonably necessary to enable us provide our Services;
  • A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution
    or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our users is among the assets transferred;
  • A third party with whom we must legally share information about you;
  • You, upon your request;
  • Other third parties with your express consent;

We may also disclose your Personally Identifiable Information:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request;
  • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of BBH, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • For any other purpose disclosed by us when you provide the information.

We may share non-Personally Identifiable Information, aggregate or anonymous data:

  • With analytics, search engine, or other service providers that help us improve our Services;
  • To advertisers and advertising networks to select and serve relevant advertisement.

In the event that we receive a request from a governmental entity to provide it with your Personally dentifiable Information, we will take reasonable attempts to notify you of such request, to the extent reasonably possible and legally permissible.

Cookies And Web Beacons

We may use cookies, beacons and similar technologies, now or in the future, to support the functionality of our
Services. This provides a better experience when you visit our Websites and allows us to improve our Services.

  • Browser Cookies. A browser cookie is a small file placed on the hard drive of your computer. We do not collect Personally Identifiable Information from browser cookies and we do not associate browser cookies with your Personal Information. You may set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you refuse all browser cookies, you may be unable to access certain parts of our Website or use certain parts of our Services. Unless you have adjusted your browser setting so that it refuses all cookies, we may issue cookies when you direct your browser to use our Services.
  • Flash Cookies. Certain features of our Services may use local stored objects called flash cookies to collect and store information about your preferences and navigation to, from and on our Website. We do not collect Personally Identifiable Information from flash cookies and we will not associate them with your Personal Information. Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse Flash cookies, please note that some parts of our Services may be inaccessible or not function properly.
  • Web Beacons. Our Website and e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us to, for example, count users who have visited those pages or opened an e-mail and for other related website statistics.

Your Choices

You may have the opportunity to receive certain communications from us related to our Services. If you provide
us with your email address in order to receive communications, you can opt out at any time by following the instructions at the bottom of our emails. Please note that certain emails may be necessary for the operation of our Services. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.

Certain websites you visit may provide options regarding advertisements you receive. For more information or to opt out of certain online behavioral advertising, please visit http://www.aboutads.info

Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Services do not currently change the way they operate based upon detection of a Do Not Track or similar signal.

Please note that we cannot control how third party websites or online services you visit through our Services respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

You may opt out of internet-based advertisement from our Services by contacting Privacy@BBHSolutions.com. By opting out of internet-based advertisement, you will no longer receive advertisements that are relevant to you, however, some advertisers may still be able to serve advertisement to you through the internet. Opting out of internet based advertisement also does not remove browser cookies, flash cookies or web beacons on your computer or electronic device. Please also note that you may need to opt out of internet-based advertisement in the future if you remove our cookies from your computer or electronic device.

You may opt out of our direct telemarketing contacts by requesting our representative to remove you from our direct telemarking list. Please note that opting out from our direct telemarketing contacts does not limit us from contacting you for other purposes, including those contacts that are reasonably necessary to provide you with our Services. If you decide to opt out of our direct telemarketing contacts, allow a reasonable time for us to process your request and do not hesitate to contact us at Privacy@BBHSolutions.com if you encounter any problems with your request. The FTC also maintain a National Do Not Call Registry at www.donotcall.gov/register/reg.aspx. By registering your number with the FTC may also limit our direct marketing contacts to that number.

To review or correct your Personally Identifiable Information, please contact us at Privacy@BBHSolutions.com.

Securing Your Information

The security of your information is important to us and we have established administrative, technical and physical controls designed to secure the information we collect and to prevent unauthorized access or disclosure. Unfortunately, no system can guarantee complete security of your information. Although we will do our best to protect your information, we cannot guarantee against access to your information, including your Personally Identifiable Information by unauthorized third parties. The security of your data transmitted to or through our Services is at your own risk.

Children

Our Services are not directed toward children under 13 years of age nor do we knowingly collect information from children under 13. If you are under 13 years of age, you are not permitted to submit any personally identifiable information to us.

Links to Third Party Sites

Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers
and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check the policies applicable to a website you access via our Services before you submit any personal data to such website

If you are a California residents, you may contact Privacy@BBHSolutions.com to request certain information regarding how we share Personally Identifiable Information to third parties for their direct marketing purposes.

Interpretation

We may enter into written agreements with you that contain specific provisions related to the confidentiality, security or other handling of information. In the event that the provisions of the written agreements differ from or conflict with the provisions of this Privacy Policy, the terms of the written agreements will apply.

Changes to Our Privacy Policy

We may change these Privacy Policy from time to time to align with changes to our business practice and or changes to our legal requirements. Any change to this Privacy Policy will be posted on this page (www.BBHSolutions.com/legal) and will be effective with respect to you upon your use of our Services after the changes have been posted or any other indication of your consent. We will post a prominent notice on our website and provide you with appropriate choices in the event that we make a material change to this Privacy Policy. Please note, we may condition your continued access to our Services on your consent to changes to this Privacy Policy.

Contact

All questions, comments, requests and other communications regarding this Privacy Policy are welcomed and
should be directed to Privacy@BBHSolutions.com.