Your privacy is important to us

BTS group (collectively “BTS”, “we”, and “us”) is a consultancy specializing in the people side of strategy. We create transformative experiences through our platforms and help the world’s leading companies turn strategy into results.

BTS is committed to maintaining the trust and confidence of its customers and visitors to our web site. In particular, we want users to know that BTS is not in the business of selling, renting or trading email lists with other companies for marketing purposes. This notice explains how we, and carefully selected third parties we work with, will collect and use the personal information of users of our Website and Applications. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

The following key terms shall be used in this Privacy Policy:

Anonymous Information: Information that has undergone anonymization such that it can no longer be used to identify an individual and cannot be combined with other information to re-identify an individual.

Data Processor: Any natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Data Subject: Any individual who the personal data relates to

Personal Data: Any information relating to or regarding an identified or identifiable natural person or information that can be used to identify you (or your household), either alone or in combination with other information available to us. This may include your name, email address, phone number, time and location data, job title, IP address and other information associated with you

Special Categories of Data: Categories of Personal Data that require a heightened level of protection under data protection legislation in some jurisdictions because it reveals or concerns sensitive information, such as health matters, race, or ethnic origin.

Standard Contractual Clauses: Any set of contractual clauses, approved by the European Commission, for the transfer of personal data to processors established in a third country (outside of the EU/EEA) where that third country does not ensure an adequate level of protection.

Supervisory Authority: Supervisory Authority (or its equivalent under any data protection legislation) is the independent public authority with whom consumers may lodge a complaint.

The BTS Web Site Privacy Policy applies equally to all individuals visiting www.bts.com or any of its applications/platforms including:

https://*.btspulse.com
https://*.btscoach.com
https://*.momenta.com
https://*.expi.com
https://*.ltpi.com
Some custom URL’s are used for client specific platforms.

Our website may contain links to information on other web sites. We do not have any control over these other web sites, and therefore we cannot be responsible for the protection and privacy of any information that is provided while visiting those sites. Those sites are not governed by this Privacy Policy. If questions exist as to how a site uses information, consult that site’s privacy statement.

We may collect following Personal Identifiable Information (“PII”) or ask you to provide PII when you visit our website or application/platforms:

• your name and contact information, including email address and telephone number, employer company details, job title etc.
• information you give us when you use the Applications/Platforms and otherwise use our services
• location data (if you choose to give this to us), IP Address may be collected when accessing our digital platforms and is required for functionality.
• Information about how you use our website, IT, Communication and other systems
• your responses to surveys, competitions, and promotions

We generally do not collect or process Special Categories Personal Data. However, a situation could arise (such as for employment purposes) in which we may process such data.

BTS may use the PII collected from you on the Platform/Application or from e-mails you send directly to us as follows:

• To perform the services that BTS has been engaged to perform by the Client (who may be your employer)
• To respond to your inquiries, comments, questions or requests;
• To monitor and statistically analyze usage of the Application and to improve the Application and/or our product and services offerings;
• To administer the Application’s systems, to audit the Application and for other internal business purposes;
• To contact you about the Application, including, without limitation, to notify you in our discretion of changes to this Privacy Policy, the Terms of Use, or other policies that affect your use of the Web Site;
• To verify and monitor compliance with the Privacy Policy and Terms of Use;
• To comply with a judicial, administrative or similar proceeding or order such as a subpoena, search warrant, discovery request or other valid law enforcement measure or investigation;
• To protect the legal rights, interests and safety of the Application, our users or others in cooperation with copyright owners, internet service providers, wireless service providers and law enforcement agencies;
• When we employ third parties to perform functions or services on our behalf, including, without limitation, third party hosting companies, communication services and data analysts; or
• To share with and among our affiliates or in the event there is any transfer, sale, or assignment of any of our business and/or assets or in the event of any other corporate change.

BTS may also disclose personal information if required to do so by law or in the good faith belief that such action is necessary in connection with a sale, merger, transfer, exchange or other disposition (whether of assets, stock or otherwise) of all or a portion of a business of BTS and/or its subsidiaries or to

• conform to legal requirements or comply with legal process served on BTS or this web site;
• protect and defend the rights or property of BTS and this web site;
• enforce its agreements with users or a user’s organization, or
• act in urgent circumstances to protect personal safety or the public.

We apply several legal bases to ensure that our processing and use of your data is compliant with applicable laws and that we have a legal basis for processing activities as outlined below:

• Consent: By using the Site or otherwise submitting your Personal Data to us, you consent to our collection, use and sharing of your PII as described in this Privacy Policy. If you do not consent to this Privacy Policy, please do not use or submit your information through the Site.
• Legitimate Interest: We may process Personal Data where processing is necessary for our (or a third party’s) legitimate interests, where those interests are not overridden by the interests or rights and freedoms of the data subject. We will process your data based on legitimate interest, for reasons such as providing our services, responding to your queries, marketing, compliance with any applicable law etc. We may process your Personal Data using data collected from public sources. We may also, in compliance with applicable law, process your data based on legitimate interest in the employment context.
• Other Legal Basis: We may also process your data based on another legal basis such as in cases where processing is necessary to comply with legal obligations.

We may use your personal data to send you updates by email, text message telephone or post about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in using your personal data for marketing purposes. This means we do not usually need your consent to send you marketing information although we may seek your consent in some circumstances. Where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

• contacting us at data.privacy@bts.com;
• using the ‘unsubscribe’ link in emails; or
• updating your personal preferences on your account.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will not share your information for marketing purposes with any third party unless you tell us we can. BTS has intercompany agreements for sharing your personal data amongst group companies. We will always treat your personal data with the utmost respect and never sell or share it with other organizations for marketing purposes.

We use cookies and other similar technologies to collect information and support certain features of the Site. The information we collect using cookies and similar technologies is not typically personally identifiable, but we may link it to Personal Data that you provide. We may use these technologies to collect information about how visitors use the Site (such as which pages they visit and the links they use). We analyse this information to better understand our visitors’ interests and needs, and to improve the content and functionality of the Site. We may also use the information to support Site features to avoid asking you to re-enter information we already possess. We also use this information to personalize your experience when you use the Site and to improve marketing efforts, including through use of targeted advertising.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies, you may be unable to use all of the Site’s functions if your browser rejects our cookies.

For more information about our use of cookies and similar technologies, refer to our cookies statement.

BTS may share your PII to the following:

• Carefully selected third parties who provide a service to us to support our core operations, such as providing technical support, processing registrations, communicating with customers and prospective customers on our behalf (including via social media), running promotions, providing IT systems and administrative services and the development, improvement of internal systems and processes, hiring employees etc. This includes its suppliers, sub processors, service providers etc.
• Competent authorities (statutory bodies, regulatory authorities, authorized bodies who have a role laid out by law);
• Other organizations where we are legally obligated to disclose your personal information (such as requests made in the prevention and detection of crime) or where disclosure is necessary to protect the property, rights and safety of us and our staff;
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice;
• Other third parties where you have given your express consent or where we reasonably believe a third party is acting on your behalf.

BTS utilize sub processors for the provision of services to its clients. A sub processor is third party service provider or data processor engaged by BTS and will most likely have access to or process personally identifiable data supplied by the client. Sub processors will perform various functions hosting of personal data (IaaS), collaborative document storage, CRM / Scheduling, participant monitoring of leaning journey, among some. Find more information about our sub processors here.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Your privacy is important to us. BTS uses reasonable efforts and safeguards to protect the PII we collect on this Web Site from unauthorized access, use, modification or disclosure. All information that you submit through the Platform/Application is collected, stored and processed within Company-controlled databases.  We restrict access of your PII to those employees of ours and to those service providers who need to use it to manage the Platform/Application. We have implemented physical, administrative, and technical safeguards to protect your PII from unauthorized access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our systems nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. BTS is certified and compliant with the international information security standard ISO 27001:2013.

Breach Notification- It is the policy of BTS to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. When BTS is Data controller and a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents.

BTS will retain your PII for as long as you continue to use the Site, and thereafter as permitted or required by applicable law or to satisfy our business requirements. Client data is retained in accordance with the retention policy of the applicable Client master service agreement / contract

We may use a process called anonymization to make data collected by us Anonymous Information. In this case, all personal data elements will be anonymized in accordance with applicable law.

Right to information  

• Right to receive information about the processing of your Personal Data, prior to processing as well as during the processing, upon request.

Right of Access

• You have the right to request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Right to Rectification

• Where personal data is inaccurate or incomplete, you have the right to request that it be corrected or completed.

Right to Erasure

• You have the right to require that BTS erases personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing

Right to Restrict Processing

• You can exercise the right to a restriction of processing of your personal data if: You are contesting the accuracy of your Personal Data, for a period enabling us to verify the accuracy of your Personal Data; the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead; we no longer need the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; or you have objected to processing of your Personal Data, and there is a pending verification whether our legitimate grounds override your interests.

Right to Data Portability

• You have the right to request your personal data which you have provided and is being processed on the basis of consent or where it is necessary for the purpose of conclusion and performance of a contract, in machine-readable format. This right applies exclusively to Personal Data where processing is carried out by automated means

Right to Object

• Applies to cases of processing carried out in legitimate interest. the right to object to processing on grounds relating to your particular situation, and we are required to assess the processing in order to ensure compliance with all legally binding rules and applicable regulations. In case of direct marketing, we shall cease processing Personal Data for such purposes after the objection.

Automated Decision-Making Rights

• You have the right to not be the subject of automated decision-making including profiling, which produces legal effects concerning you.

This Policy may contain pages through which you can change your preferences or update your PII. You can contact BTS directly in order to:

• Update or correct the PII that we store about you;
• Direct us to render inactive on our systems all your PII; or
• Make a request related to the data subject rights listed in section 4.9.
• For any questions, concerns or complaints regarding use of personal data

We may be reached at data.privacy@BTS.com.

Please note that if you request us to render inactive your PII, we may still use aggregated non-PII, and some PII that you provided may continue to reside on backup servers and other non-active systems for data restoration purposes, and will be purged during the natural lifecycle of the backup. We will not manually delete PII from such backup media.

• Subject Access Requests are typically responded to within one month of receiving the request.

Please be aware that any information you provide to us may be transferred within and/or outside of the country of origin to another BTS location. BTS carefully reviews international data transfers before they take place to ensure that they fall within the limits of local and international laws and regulations. By using the Application or by providing us with your information, you consent to this transfer.

Our services are not directed at nor targeted towards children. If you have not reached the age of majority or are not able to enter into legally binding agreements in your country, you may use the BTS Application/Platform only with the involvement of a parent or guardian. BTS will not knowingly collect, maintain or use any personally identifiable information about children. In the event we discover that a child has responded to this Application with personally identifiable information, we will take reasonable steps to securely remove such information from our database.

This section applies to California, USA residents:

In addition to the above, California residents have the right to make the following requests with respect to their personal information under the California Consumer Privacy Act (“CCPA”):

• know what personal information is being collected about you;
• know whether your personal information is sold or disclosed, and to whom;
• say no to the sale of personal information (right to opt out);
• request deletion of your personal information; information will be deleted if no exception applies (including our right to defend our lawful interests);
• access your personal information; specific information shall be provided in a portable and, to the extent technically feasible, in a readily useable format but not more than twice in a 12-month period;
• equal service and price, even if you exercise your privacy rights (right to non-discrimination).
• Right To Opt Out Of Sale-If your personal information is subject to a sale you have the right to opt out from that sale.

To exercise any of your rights under the CCPA, please send us a request using the information in the How to Contact Us section of this Privacy Policy. We may ask you for additional information to verify your identity and reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or satisfy our legal and business requirements.

By using this Application, you accept our privacy practices as outlined in this Privacy Policy. BTS reserves the right to modify, revise or otherwise update this Privacy Policy at any time for any reason. We will post any new or revised policies on the Platform/Application, but we will only use your PII in accordance with the privacy policy that was in effect at the time it was collected, unless you consent to any new terms regarding its use. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE EXIT THIS WEB SITE IMMEDIATELY.

You can contact us by post, email or telephone if you have any questions about this privacy notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Unless otherwise indicated, this Web Site and its contents, including but not limited to all text, HTML code, CGI scripts, graphics, button images, and the site design and “look and feel,” are the property of BTS and are protected pursuant to U.S. and foreign copyright and trademark laws. By accessing this Web Site, you agree to the following terms and conditions, which govern this Web Site:

• • This Web Site and the material on this Web Site may not be modified, copied, distributed, republished, downloaded, uploaded or commercially exploited in any manner without the prior written consent of BTS except that you are permitted to download a copy of any of the materials on this Web Site on a single computer for personal noncommercial use, provided no copyright, trademark or other proprietary notices are removed. No intellectual property or other rights in or to this Web Site or its contents are transferred to you.

• • The information on this Web Site is provided solely for illustrative purposes and does not create any business, contractual or employment relationship.

• • THE MATERIAL ON THIS WEB SITE IS PROVIDED ’AS IS’ AND IS WITHOUT WARRANTY OF ANY KIND. BTS DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF TITLE, NON-INFRINGEMENT, MERCHANTIBILITY AND FITNESS FOR A PARTICULAR PURPOSE, WITH RESPECT TO THIS WEB SITE AND THE MATERIAL ON THIS WEB SITE. BTS ALSO MAKES NO REPRESENTATIONS OR WARRANTIES AS TO WHETHER THE INFORMATION ACCESSIBLE ON THIS WEB SITE IS ACCURATE, COMPLETE OR CURRENT.

• • TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAWS, IN NO EVENT SHALL BTS BE LIABLE FOR ANY DAMAGES OF ANY KIND OR CHARACTER, INCLUDING WITHOUT LIMITATION ANY COMPENSATORY, INCIDENTAL, DIRECT, INDIRECT, SPECIAL, PUNITIVE, OR CONSEQUENTIAL DAMAGES, LOSS OF USE, LOSS OF DATA, LOSS OF INCOME OR PROFIT, LOSS OF OR DAMAGE TO PROPERTY, CLAIMS OF THIRD PARTIES, OR OTHER LOSSES OF ANY KIND OR CHARACTER, EVEN IF BTS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES, ARISING OUT OF OR IN CONNECTION WITH THIS WEB SITE OR THE CONTENTS OF THIS WEB SITE.

• • The posting of any content or material to this Web Site and the creation of a link from this Web Site to any other Web Site are expressly prohibited without the prior written consent of BTS.

• • BTS does not regularly review materials on Web Sites linked to this Web Site and does not necessarily endorse the materials appearing on any linked Web Sites.

• BTS reserves the right to change these terms and conditions at any time by updating this posting. Use of this Web Site following any such changes shall constitute acceptance of such changes.

This policy was last updated on March 29, 2023. For a list of exact changes, please reach out to data.privacy@BTS.com.