Your privacy is important to us
BTS takes your privacy seriously
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.
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.
Some custom URL’s are used for client specific platforms.
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:
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
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:
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:
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.
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.
BTS may share your PII to the following:
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 of Access
Right to Rectification
Right to Erasure
Right to Restrict Processing
Right to Data Portability
Right to Object
Automated Decision-Making Rights
This Policy may contain pages through which you can change your preferences or update your PII. You can contact BTS directly in order to:
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.
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”):
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:
|Our contact details
114 53 Stockholm
|email@example.com or submit your query on our Contact Us page here.
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 policy was last updated on March 29, 2023. For a list of exact changes, please reach out to data.privacy@BTS.com.