Privacy Policy

Privacy Statement, effective as of Aug 1, 2023

1. Responsible blumanager entity

Blumanager  (“blumanager, “we”, “us”, or the “Company”) are responsible for the processing of your Personal Data as described in this Privacy Statement, unless specified otherwise, and act as the controller of such Personal Data.

This Privacy Statement does not apply to the extent we process Personal Data in the role of a processor or service provider on behalf of our customers, including where we offer to our customers various products and services through which our customers (or their affiliates): (i) create their own websites and applications running on our platforms; (ii) sell or offer their own products and services; (iii) send electronic communications to others; or (iv) otherwise collect, use, share or process Personal Data via our products and services.

For detailed privacy information related to a blumanager customer or a customer affiliate who uses blumanager products and services as the controller, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Statement. For more information, please also see Section 10.3 below.

2. Processing activities covered

This Privacy Statement applies to the processing of Personal Data collected by us when you:

  • Visit our websites that display or link to this Privacy Statement;
  • Visit our branded social media pages;
  • Receive communications from us or otherwise communicate with us, including but not limited to emails, phone calls or texts;
  • Use our products and services where we act as a controller of your Personal Data;
  • Are employed by a customer of our products and services where your information has been shared with us in our capacity as a controller (for example, during the contracting process); 
  • Participate in surveys, research or other similar data collection facilitated by us.

3. What Personal Data do we collect?

  3.1 Personal Data we collect directly from you

  The Personal Data we collect directly from you may include identifiers, professional or   employment-related information, financial account information, commercial information, visual information, and internet activity information, among others. We may collect such information in the following situations:

Situations

Categories of Personal Data

If you express an interest in obtaining additional information about our services; request customer support, use our “Contact Us” or similar features; register to use our websites or to receive communications; sign up for an event, webinar or contest; participate in a program, training, certification or survey; use our products and services; download certain content; or are employed by a customer of our products and services where your information has been shared with us

Contact information, such as your name, job title, company name, address, phone number, email address, username and password, other information you have voluntarily chosen to share

If you attend an event

Attendee badge information which may include name, title, company name, address, country, phone number and email address, image and video

If you give your explicit consent and only for specified events, your biometric information, such as an image of your facial features for identification purposes

During the Covid-19 pandemic, this may also include health status, including your temperature, COVID-19-related symptoms, exposure to COVID-19 positive individuals, vaccination status, testing results, and recent travel history

If you interact with our websites or emails

Information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers), which may qualify as Personal Data (please see Section 4 below) using cookies, web beacons, or similar technologies

If you use and interact with our products and services

Information about your device and your usage of our services through log files and other technologies, some of which may qualify as Personal Data (including Usage Data) (please see Section 4 below

If you communicate with us via a phone call

Information such as your name, voice and any other Personal Data voluntarily share

If you voluntarily submit certain information to us, such as filling out a survey, responding to a questionnaire or participating in other forms of research

Information you have provided as part of that request, which may include Personal Data and special categories of Personal Data, to the extent you voluntarily choose to provide it

 

If you provide us, our service providers or our affiliates with any Personal Data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us by using the information in Section 13 below.

4. What Device and Usage Data do we process?

We use common information-gathering tools, such as tools for collecting data, cookies, web beacons, pixels, and similar technologies to collect information that may contain Personal Data as you navigate our websites, our services, or interact with emails we have sent to you.

4.1 Device and Usage Data

As is true of most websites, we gather certain device information when individual users visit our websites. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, Internet service provider, mobile carrier, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the websites. This information is used for the purposes set out in section 5 of this Privacy Statement below. 

In addition, we gather certain information as part of your use of our products and services (“Usage Data”). This information may include: (i) identifiers, such as user ID, organization ID, username, email address and user type; (ii) commercial information; and (iii) internet activity information such as IP address (or proxy server), mobile device number, device and application identification numbers, location, language, browser type, Internet service provider or mobile carrier, user interactions such as the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system type and version, system configuration information, date and time stamps associated with your usage and details of which of our products and product versions you are using. This information is used for the purposes set out in detail in section 5 of this Privacy Statement below. In addition, we may use aggregated Usage Data for other internal business purposes, such as to identify additional customer opportunities and to ensure that we are meeting the demands of our customers and their users. Please note that this Usage Data is primarily used to identify the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers. 

4.2 Cookies, web beacons and other tracking technologies on our website and in email communications

We use technologies such as web beacons, pixels, tags, and JavaScript, alone or in conjunction with cookies, to gather information about the use of our websites and how people interact with our emails.

When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer browsing preferences, and improve and customize your browsing experience.

We use both session-based and persistent cookies on our websites. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off. To change your cookie settings and preferences for one of our websites, click the Cookie Preferences link in the footer of the page. You can also control the use of cookies on your device, but choosing to disable cookies on your device may limit your ability to use some features on our websites and services.

We also use web beacons and pixels on our websites and in emails. For example, we may place a pixel in a marketing email that notifies us when you click on a link in the email. We use these technologies to operate and improve our websites and marketing emails. – please see more details in the “Advertising Cookies” row in the table below. For instructions on how to unsubscribe from our marketing emails, please see Section 10.4 below.

The following describes how we use different categories of cookies and similar technologies and your options for managing the data collection settings of these technologies:

Type of Cookies

Description

Managing Settings

Required cookies

Required cookies are necessary for basic website functionality. Some examples include: session cookies needed to transmit the website, authentication cookies, and security cookies.

If you have chosen to identify yourself to us, we may place on your browser a cookie that allows us to uniquely identify you when you are logged into the websites and to process your online transactions and requests.

Because required cookies are essential to operate the websites, there is no option to opt out of these cookies.

 

 4.4 Opt-Out from the setting of cookies on your individual browser

In addition to using the user preference center, in many cases you may opt-out from the collection of non-essential device data on your web browser (see Section 4.1 above) by managing your cookies at the browser or device level. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the websites.

While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites. blumanager takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

4.5 Social Media Features

Our websites may use social media features, such as the “Tweet” button and other sharing widgets (“Social Media Features”). Social Media Features may allow you to post information about your activities on our website to outside platforms and social networks. Social Media Features may also allow you to like or highlight information we have posted on our website or our branded social media pages. Social Media Features are either hosted by each respective platform or hosted directly on our website. To the extent the Social Media Features are hosted by the platforms themselves, and you click through to these from our websites, the platform may receive information showing that you have visited our websites. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile.

Blumanager also allows you to log in to certain of our websites using sign-in services. These services authenticate your identity and provide you the option to share certain Personal Data from these services with us such as your name and email address to pre-populate our sign-up form.

Your interactions with Social Media Features are governed by the privacy policies of the companies providing them.

4.6 Telephony log information

If you use certain features of our services on a mobile device, we may also collect telephony log information (like phone numbers, time and date of calls, duration of calls, SMS routing information and types of calls), device event information (such as crashes, system activity, hardware settings, browser language), and location information (through IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers).

5. Purposes for which we process Personal Data and the legal bases on which we rely

We collect and process your Personal Data (including, where legally permissible, special categories of Personal Data) for the following purposes and relying on the following legal bases:

Purpose

Description

Legal basis

Providing our websites (including our social media pages)

We process your Personal Data to operate and administer our websites and to provide you with the content you access and request 

Our legitimate interest in providing online content to our customers and prospective customers regarding our service offering and related information

Improving our websites

We process your Personal Data to analyze overall trends and help us improve the user experience on our websites

Our legitimate interest in providing a relevant and well-functioning website for the benefit of our website visitors 

Promoting the security of our websites

We process your Personal Data by tracking use of our websites and verifying and investigating activity

Our legitimate interest in promoting the safety and security of our websites and in protecting our rights and the rights of others

Registering visitors 

We process your Personal Data, including registration information and associated non-disclosure information, for security reasons

Our legitimate interest in protecting our offices, staff, visitors and our confidential information against unauthorized access

Ensuring the safety and security of our employees, events and premises

We process your Personal Data where necessary based on a credible threat to our employees, events or premises

 

Our legitimate interest in protecting our employees, events and premises

Sending communications

We process your Personal Data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS or push notifications, information about our products, news or events) about us, our affiliates and partners

Our legitimate interest in conducting direct marketing or where you have provided your prior consent (please see Section 10 below to learn how you can control the processing of your Personal Data by blumanager for marketing purposes)

Recording phone calls

We process your Personal Data, including recording phone calls (in accordance with applicable laws) for training, quality assurance, and administration purposes

 

If required under applicable law, we will give you the option to object to a call being recorded

Consent or our legitimate interest in maintaining the high quality of our phone calls with users

Handling contact and user support requests

We process your Personal Data, if you fill out a “Contact Me” web form or request user support, or if you contact us by other means including but not limited to via phone

Necessary for the performance of a contract or our legitimate interest in fulfilling your requests and communicating with you

Providing our services 

We process your Personal Data to perform our contract with you for the provision of our services and to satisfy our obligations under the applicable terms of use

Necessary for the performance of a contract or our legitimate interest to provide and administer our services

Developing and optimizing the performance of the services

We process your Personal Data to develop, optimize, and improve the performance of the services

Legitimate interest to develop services and ensure that the services are performing in line with customer expectations; if special categories of Personal Data are processed, where the Personal Data is manifestly made public by the data subject

Providing personalized interactions

We process your Personal Data to customize our interactions with you

Legitimate interest to offer the best-in class services to our customers

 

Managing our customer and user accounts

We process your Personal Data (including Usage Data) to manage customer and user accounts generally, such as billing, customer correspondence and customer relationship management

Necessary for the performance of a contract or our legitimate interest in the management of customer and user accounts

Managing usage and licensing compliance

We process your Personal Data (including Usage Data) to assess and manage usage and licensing compliance with the applicable terms of use of our services

Necessary for the performance of a contract or our legitimate interest in managing the provision of our services to customers

Preparing internal reports and business modeling 

We process your Personal Data (including Usage Data) for internal reporting and business modeling purposes (e.g., forecasting, revenue, capacity planning, product strategy)  

Our legitimate interest in the management of our business operations

Maintaining our security 

We process your Personal Data (including your Usage Data) for the purposes of maintaining Blumanager’s own security, including investigating, detecting and preventing suspicious activity, fraud and cybercrime that may affect blumanager or its services

Our legitimate interest in promoting the safety and security of blumanager generally and to protect our rights and the rights of others

Undertaking financial reporting 

We process your Personal Data (including your Usage Data) for the purposes of financial reporting

Our legitimate interest in meeting our obligations associated with the reporting of our finances

Managing, and participating in, webinars, contests, programs, training, certifications or promotions

We process your Personal Data if you register for a webinar, contest, promotion, training, certification or a program.

In some cases where the training or certification is through your employer, we will share your we will share your Personal Data with your employer

Some webinars, contests, programs, trainings, certifications and promotions have additional rules containing information about how we will process your Personal Data

Consent, necessary for the performance of a contract or our legitimate interest in providing the webinar, contest, promotion, training, certification or promotion

Managing payments

If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you

Necessary for the performance of a contract

Administering surveys and conducting research

We process your Personal Data (including, where legally permitted, special categories of Personal Data) in order to meet the goals set out in surveys or research as well as to analyze our compliance with internal policies

Consent or explicit consent (if required under applicable law) or our legitimate interest in conducting the survey or research based on its stated goals (where no special categories of Personal Data are in scope)

Participating in a blumanager community, such as that focused on open-source development 

We process your Personal Data, such as your username associated with your community account, in order to host and maintain the community for the benefit of its members

Our legitimate interest in hosting and maintaining such a community for the benefits of its members, as well as in order to inform you of program changes that are important to your participation or relate to additional security measures

Collecting diversity information

We process your Personal Data (including special categories of Personal Data) to the extent you voluntarily consent to provide it to meet our broader community goals related to diversity and equality of opportunity 

Consent or explicit consent (if required under applicable law)

Complying with legal obligations

We process your Personal Data (including Usage Data) when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights

Legal obligation or our legitimate interest in protecting against misuse or abuse of our websites or services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, responding to lawful requests, or for auditing purposes


If we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.

6. Who do we share Personal Data with?

We may share your Personal Data as follows:

  • Service providers: With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, events planning, customer support and data enrichment for the purposes and pursuant to the legal bases described above in Section 5. Contracted service providers may also deliver artificial intelligence and generative artificial intelligence capabilities to analyze data, determine trends, make predictions and create AI-generated responses or other content for the purposes and pursuant to the legal bases described above in Section 5; 
  • Event sponsors: If you attend an event or webinar organized by us, or download or access an asset on our website, we may share your Personal Data with sponsors of the event. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not wish for your information to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with Section 10 below;
  • Public authorities: With public and government authorities, to the extent we are compelled to disclose Personal Data to comply with our legal obligations.

8. Children

Our websites and services are not directed at children. We do not knowingly collect Personal Data from children under the age of 13. We do not knowingly collect Personal Data for children between 13-18 unless we have obtained consent from a parent or guardian or such collection is subject to a separate agreement with us or the visit by a child is unsolicited or incidental. If you believe we have mistakenly or unintentionally collected Personal Data of a minor without appropriate consent please contact us by using the information in Section 13 below and we will take steps to delete their Personal Data from our systems.

9. How long do we keep your Personal Data?

We may retain your Personal Data for a period of time consistent with the original purpose of collection (see Section 5 above) or as long as required to fulfill our legal obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

For more information on data retention periods, please contact us by using the information in the Section 13 below.

10. Your rights relating to your Personal Data

10.1 Your rights

You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

  • Access your Personal Data held by us;
  • Know more about how we process your Personal Data;
  • Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
  • Erase or delete your Personal Data;
  • Restrict our processing of your Personal Data;
  • Transfer your Personal Data to another controller, to the extent possible;
  • Object to any processing of your Personal Data;
  • Opt out of certain disclosures of your Personal Data to third parties;
  • Know what categories of Personal Data are shared for delivering advertisements on non-blumanager websites, applications, and services and the categories of recipients of such Personal Data;
  • Opt out of the sharing of your Personal Data for delivering advertisements on non-blumanager websites, applications, and services;
  • If you’re under the age of 16, or such other applicable age of consent for privacy purposes in relevant individual jurisdictions, opt in to certain disclosures of your Personal Data to third parties; 
  • Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”);
  • Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal; and
  • Not be discriminated against for exercising your rights as described above.

 

Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection.

Please note that Automated Decision-Making currently does not take place on our websites or in our services.

 

10.2 How to exercise your rights

To exercise your rights, please contact us by using the information in Section 13 below. Your Personal Data may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, considering the complexity and number of requests we receive. If you are an employee of a blumanager customer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information.

Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles.

To update your billing information, discontinue your account or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in Section 13 below.

10.3 Your rights relating to customer data

As described above, we may also process Personal Data submitted by or for a customer to our products and services. To this end, if not stated otherwise in this Privacy Statement or in a separate disclosure, we process such Personal Data as a processor on behalf of our customer (and its affiliates) who is the controller of the Personal Data (see Section 1 above). We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Statement. If your data has been submitted to us in our role as a processor by or on behalf of a blumanager customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. Because we may only access a customer’s data upon their instructions, if you wish to make your request directly to us, please provide us the name of the blumanager customer who submitted your data to us. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.

10.4 Your preferences for email and SMS marketing communications

If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from blumanager by clicking on the “unsubscribe” link located on the bottom of blumanager marketing emails, by replying or texting ‘STOP’ if you receive blumanager SMS communications.

You may also turn off push notifications on blumanager apps on your device, or unsubscribe by contacting us using the information in the “Contacting us” section, below.

Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.

10.5 Your preferences for telemarketing communications

If you want your phone number to be added to our internal Do-Not-Call telemarketing register, please contact us by using the information in Section 13 below. Please include your first name, last name, company and the phone number you wish to add to our Do-Not-Call register.

Alternatively, you can always let us know during a telemarketing call that you do not want to be called again for marketing purposes.

11. How we secure your Personal Data

We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use.

While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in Section 13 below.

12. Changes to this Privacy Statement

We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes.

We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.

13. Contacting us

To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement or our privacy practices please email us at info1@blumanagear.com, call us at +52 818.026.3397 or write to us at:

Bosques de los Fresnos 121

Colonia Bosques de Valle Alto 

Monterrey, Nuevo Leon, MEX 

When you contact us, please indicate in which country and/or state you reside.