Data Privacy Policy

Last Updated On: 23^rd of November 2020

Effective Date: 1^st of December 2020

@ Copyright BPN Solutions, [2020]. All rights reserved; reproduction, adaptation, or translation without permission is prohibited except as allowed under the International copyright laws. All the text, graphics, design, content, and other works are the copyrighted works of BPN Solutions.

This Privacy Policy shall be read in juxtaposition, harmony and in furtherance of the Data Processing Policy and Terms and Conditions of the BPN Solutions.

Click here to read our “Data Processing Policy”
Click here to read our “Terms and Conditions”

We consider the privacy of our visitors to be extremely important. This Data Confidentiality Policy describes in detail how BPN Solutions Pty Ltd (“we” “us” or “our”) may collect, process, store, use and disclose (collectively, “utilise”) the data that we collect from you in connection with your use of our website (www.bpn-solutions.com) (the “Site”), hotel experience cloud-based platform, mobile applications, and related software, which is made available through third-party application providers and our website, (collectively, including the Site, our “Services”). This Data Confidentiality Policy also identifies your rights with respect to your personal information.

BPN Solutions subscribes to "Australian Privacy Principles" “(APPs)” made pursuant to the Australian Privacy Act, 1988, and the Spam Act, 2003, which provide a set of principles to be applied when working with personal information. All information provided and stipulations given herein shall be read in conformity with APPs. If there is any contradiction between contents of this Policy and APPs, the later shall be deemed to be prevailing over the former.

We may update or modify this Data Confidentiality Policy at any time, by posting the amended version, including the effective date of the updated version, on our Site and by providing a notification upon login to the Services.

By accessing and/or using the Services (including the Site), you accept and agree to this Data Confidentiality Policy and the use of your data and personal information as described in this Data Confidentiality Policy. If you do not agree to be bound by this Data Confidentiality Policy or any subsequent modifications, you should not access or use the Services or interact with any other aspect of our business.

This Data Confidentiality Policy contains the following information, which you can access by scrolling down:

What Information We collate about You and why.
Information We collect automatically.
How We may use your information.
With whom We may share your information.
Your rights and options regarding your personal information.
How We safeguard your personal information.
How long we store your personal information.
Links
Minors
Special notice regarding data transfers.
Governing law and jurisdiction.

What Information We collate about You and why.

Information we collate

We obtain information about you and your use of our Services when you visit our Site, when you use the Services, when you register a customer or user account with us or create or modify your profile; when sign up to receive communications or a product from us, or if you obtain support services or communicate with us through the “Contact Us” form or from the use of any of the tabs on our Site. We also collect and collate your contact information, and in some cases, billing information when you register for the Services. We keep track of your preferences to enhance your user experience.

We will not use or share your information with anyone except as described in this Data Confidentiality Policy. Capitalized terms that are not defined in this Data Confidentiality Policy have the meaning given them in our Terms and Conditions.

We use the information every day to keep our team organized, connected, and focused on results. Specifically, we use the information to operate, maintain and provide you the features and functionality of the Service, to analyse how the Service is used, diagnose service or technical problems, to personalize content, to assist you to efficiently access your account, and to monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns.

Ensuring our platform remains secure is vital to protecting our own data, and protecting your information is our highest priority. Our employees are expected to respect the terms of our data confidentiality policies, and access rights are based on employee’s job function and role.

You also provide us information in the content that you post on our Site. Your content and metadata about your Content may be viewed by other users in accordance with your settings on the Service. We can remove any information you post for any reason or no reason. Unless Content is made viewable in accordance with your settings on the Service, we will not view your Content except: (i) to maintain, provide or improve the Service; (ii) to help you and resolve your support requests; or (iii) as we believe, in our sole opinion, is necessary to comply with or avoid the violation of applicable law or regulation or to cooperate with law enforcement.

The information we collect can include personal information (as described below) or non-personal information, which is information that does not identify or relate to an individual.

Personal information means information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We collect information through any correspondence that you provide to us whether through email, mail, phone calls, or through our Services. Information that you provide might include, but is not limited to, the following: (a) first and last names; (b) demographic information; (c) mailing address; (d) email address; (e) phone number; (f) credit card number; (g) job title; (h) company name; and (i) other information that personally identifies you.

We do not consider personal information to include information that can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.

We collect information from you both when you provide it voluntarily and also automatically when you visit the Site or otherwise use our Services. We may engage in search retargeting advertising, which means that our vendors who provide this service to us may collect information about the keywords you enter into certain search engines, your IP address, and your browser information and use it to display interest-based advertisements to you. Most of the personal information we receive relates to your use and participation in the Services as part of performing your job duties for your employer or employing organization, which has licensed the Services from us. We may also receive information about you if the hotel transmits your information through the Services.

In some instances, we automatically collect certain types of information when you visit our Site or use our Services or correspond with us. Automated technologies may include the use of web server logs (to collect IP addresses), “cookies,” as further described below.

How to contact us and update your communication preferences and/or information:

You can update your communication preferences and information in the following ways by: If you are someone authorized to use the Services under an agreement between us and your employer (an “Authorized User”), you may update your contact information in your profile or account through our Services or manage push notifications on your mobile device through preferences in the application or device settings. Whether or not you are an Authorized User, you may contact us at the e-mail or postal address below to update your communication preferences and information.

You may access, by request, to the personal information collected by us about you. And we may make any changes, according to our policies, if indicated by you, in your personal information to keep it up to date. However we may not grant you access to your personal information if it compromises privacy of others or prejudices any legal procedure.

Additionally, if you have any questions or concerns about our use of your personal information, please do not hesitate to contact us through any of the methods listed below.

Mail:
BPN Solutions Pty Ltd

PO Box 243, Petersham, NSW 2049, Australia

Email: legal@bpn-solutions.com

When and how do we collect your information?

Like many other Web sites, we make use of log files. These files merely logs visitors to the site – usually a standard procedure for hosting companies and a part of hosting services’ analytics. The information inside the log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and possibly the number of clicks. This information is used to analyze trends, administer the site, track user’s movement around the site, and gather demographic information. IP addresses and other such information are not linked to any information that is personally identifiable.

What information do we collect from you?

Information collected when you sign up to schedule a demo
Categories of information	Description of category
Started and Contact Sales Information	This is the personal information that is provided by you or collected by us to enable you to sign up to schedule a demo of our Services. This includes your name, email address, job title and company, phone number, and any personal information that you choose to enter into the blank message box.

Information collected when you contact us through the “General Inquiries” online form
Categories of information	Description of category
General Inquiries Information	This is the personal information that is provided by you or collected by us to enable us to respond to your inquiry. This includes your name, email address, and any personal information that you choose to enter into the blank message box.

Information collected when you contact us through the Support form
Categories of information	Description of category
Support Information	This is the personal information that is provided by you or collected by us to enable us to respond to request for Support. This includes your name, email address, phone number, Authorized username, hotel name, and any personal information that you choose to enter into the blank message box.

Information collected when you subscribe to or comment on our newsletters on our website
Categories of information	Description of category
Newsletter Registration Information	This is the information that is provided by you and collected by us when you choose to comment on a newsletter. We do not require you to provide your personal information to comment, so comments would be non-personal information unless you choose to include personal information.
Newsletter Comments	This is the information that is provided by you and collected by us when you choose to comment on a newsletter. We do not require you to provide your personal information to comment, so comments would be non-personal information unless you choose to include personal information.

Information collected through use of our Services
Categories of information	Description of category
Account Registration Information	This is the personal information that is provided by you or collected by us to enable you to login and access your account and our Services. This includes your name, email address, job title, and company. It may also include the IP address of the device you use to log in. Some of the personal information we will ask you to provide is required in order to create your account. You also have the option to provide us with some additional personal information in order to make your account more personalized.
Services Usage Information	This can be personal information and non-personal information that is collected about you when you are using our Services, and this may include: Information about your Service plan. Information about your interactions with our Services, which includes the date and time of any information you enter into our Services, and your interactions with other Authorized Users of our Services. Authorized User content you post to our Services including messages you send and/or receive through our Services and your interactions with our customer service team. Technical data which may include URL information, cookie data, web beacons and other tracking technology information, your IP address, the types of devices you are using to access or connect to our Services, unique device IDs, device attributes, network connection type (e.g., WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system. Further details about the technical data that is processed by us can be found below.
Anonymized Information	We use anonymized and aggregated information that may be created or derived from your personal information or usage of the Services for purposes that include data analysis, improving our Services, advertising, and developing new features and functionality within our Services.

Information collected through search retargeting practices
Categories of information	Description of category
Advertising Information	This information includes keywords you entered into a search engine, the IP address associated with your device, and your browser information. This information may be collected by vendors offering search retargeting advertisements.

Information We collect automatically.

Cookies: We use cookies to store information about visitors’ preferences, to record user-specific information on which pages the site visitor accesses or visits, and to personalize or customize our web page content based upon visitors’ browser type or other information that the visitor sends via their browser.

When you use the Service, we may send one or more “cookies” – a small data file – to your computer or mobile device to uniquely identify your browser and let us help you log in faster and enhance your navigation through the site by collecting information about the pages you view, the Services functions that you access, the buttons and icons you click, and to remembering your login information and Services settings. Cookies also help us learn which areas of our Services are useful and which areas need improvement.

A cookie may convey anonymous information about how you use the Services to us. A persistent cookie remains on your hard drive after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

The following cookies are on our Site:

Cookie	Description
_gat	Google Analytics cookie used to improve performance by limiting the collection of data on high traffic websites
_ga	Google Analytics cookie used to improve performance by distinguishing users and calculating visitor, session, and campaign data
_gid	Google Analytics cookie used to improve performance by distinguishing users
PHPSESSID	PHP language cookie that is general purpose identifier used to maintain user session variables and is necessary for functioning of the Services

Our Advertising Partners

Some of our advertising partners may use cookies and web beacons on our site. Our advertising partners include: [for details see website www.bpn-solutions.com].

How We may use your information.

We may use non-personal information without restriction. Without limiting the foregoing, we reserve the right to use and publish your non-personal information and to perform statistical analyses of user behavior (on an aggregate basis) in order to measure usage of our Site and Services. We may share non-personal information, such as demographics and general analytics regarding use of our Site and other Services, with existing and prospective business partners, clients, advertisers, or third-party service providers.

We will only use your personal information for the purposes identified below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose described here. In the table below, we have set out some of the reasons why we process your personal information, the associated legal basis we generally rely upon to legally permit us to process your information, and some of the categories of information (identified in “The information we collect about you” above) used for these purposes:

Why We process your information	Legal basis for the processing purpose	Categories of information used by us for the processing purpose
To respond to your request, to fulfil the purpose for which you provide the information, or to provide the Services to you in accordance with our contract with the hotel you represent or in which you are a guest.	Performance of a contract	Account Registration Information, Get Started and Contact Sales Information, Support Information, Services Usage Information, Anonymized Information
To personalize and improve your experience with our Services, for example by providing customized or localized content, recommendations, support, and features through our Services.	Legitimate interest	Account Registration Information, Support Information, Services Usage Information, Anonymized Information
To ensure technical functionality and proper operation of our Services, for example by reviewing information associated with stalled or crashed pages experienced by users allowing us to identify and fix problems and give you a better experience.	Legitimate interest	Service Usage Information, Support Information, Anonymized Information
To compile overall statistics about how users interact with the Services and content they find useful in order to enable us to analyze how the Site and other Services are used and how we can improve it	Legitimate interest	Services Usage Information
To monitor the security of our Services and prevent and/or investigate security breaches or other potentially prohibited activities.	Legitimate interest	Account Registration Information, Services Usage Information, Anonymized Information
To improve our Services and develop new products and services, for example by reviewing your access to and use of our Services, including your interactions with applications or functionality made available, linked to or offered through, our Services to learn what is most valuable and helpful to you.	Legitimate interest	Services Usage Information, Anonymized Information
To communicate with you for Services-related purposes, such as regarding support issues, password retrieval, and guides and information about your Services account.	Performance of a contract, Legitimate interest	Account Registration Information, Support Information, Services Usage Information
To communicate with you, either directly or through one of our service providers, for the following purposes: to respond to a request, marketing, research, to schedule a demo of our Services, to provide our newsletter, or other promotional purposes, via email, Notifications or other messages, consistent with any permissions you may have communicated to us.	Consent, Legitimate interest	Get Started and Contact Sales Information, Account Registration Information, General Inquiries Information, Job Application Information, Support Information, Newsletter Registration Information
To provide you with features or other content based on your location.	Legitimate interest	Services Usage Information
To comply with our legal obligations, including assessing compliance with our regulatory requirements (e.g., using user data in the aggregate to assess our obligations under applicable data security and privacy requirements)	Legal obligations	Account Registration Information, Services Usage Information, Anonymized Information
To carry out our obligations and enforce our rights	Legitimate interest, Contract	Account Registration Information, Services Usage Information, General Inquiries Information, Get Started and Contact Sales Information
In any other way described when the information is collected	Legitimate interest, Consent	All information collected

Our vendors may use Advertising Information to serve interest-based advertisements about us and our Services to you through our vendors’ advertising display network(s).

To the extent you are in a jurisdiction that does not require us to identify a specific legal basis for processing personal information, or to associate the information processed with the basis and the manner in which it is used, we reserve the right to use all of the information collected in any of the ways disclosed above and in any way permitted.

With whom We may share your information.

In connection with our Services, we may share your personal information with the following types of recipients and for the following reasons:

Categories of recipients	Reasons for sharing
Service providers and others	We use service providers to operate our software and infrastructure; in particular providers which host, store, manage, and maintain our Services, its content and the data we process. This includes our email marketing, text messaging component for our Services, and information security service providers.
Hotel employers, hotel owners and other business Affiliates	We may share your personal information with your employer (or organization on whose behalf you are accessing and using the Services) or with the hotel of which you are a guest to aid such Organizations in their business operations and decision making, as well as organizational use of the Services, which may include monitoring and analyzing your use of the Services.
Data analytics providers	We will share your personal information to create general data analytics regarding usage of our Services on an aggregate basis and without personal identifiers. For example, we use Google Analytics, a service provided by Google, Inc., to gather information about how you and other users engage with the Services.
Law enforcement and data protection authorities	We will share your personal information with third parties where required by law (including to respond to valid legal process such as a search warrant or a court order), where it is necessary in connection with our Services or where we have another legitimate interest or legal obligation in doing so.
Other legal or regulatory authorities	We will share your personal information for us to comply with our legal obligations, including assessing compliance with our regulatory requirements (e.g., using customer order information in the aggregate, including revenues generated in connection with our regulatory tax requirements).
Buyer or successor of our business	We will share your personal information with any buyer or successor in the event of a merger, reorganization, dissolution, or other sale or transfer of title.

We do not share your personal information with third parties for their direct marketing purposes unless you first affirmatively agree to such disclosure and then only unless and until you thereafter opt out of such disclosure.

Your rights and options regarding your personal information.

General

You can opt out from receiving future marketing communications from us at any time by:

Using the unsubscribe function in the email you receive from us; or
Contacting us as set forth under “How to contact us” above.

You can choose whether to accept cookies and/or whether to receive alerts when cookies are being sent by changing the settings on your browser or device. However, if you choose to disable cookies, your experience with our Services may be impaired and some features may not work as they were intended.

If we serve interest-based advertisements using Advertising Information through search retargeting techniques offered by Google, the advertisements may contain notice labels.

We do not track customers over time and across third party websites to provide targeted advertising. You may select a “do not track” setting on your web browser. However, these features are not yet uniform, so we do not currently respond to such features or signals. Therefore, if you select or turn on a “do not track” feature in your web browser, we and our third-party providers may continue collecting information about your online activities as described in this Data Confidentiality Policy.

You may access, correct, and delete certain personal information we have collected about you by logging in and modifying your profile (if you are an Authorized User) and/or contacting us via one of the means set forth in the “How to contact us” section above. We may not be able to delete your personal information without deleting your account and we may not accommodate a request to change or delete information if we believe doing so would violate any law or legal requirement or cause the information to be incorrect.

If you have consented to our disclosure of your personal information to third parties for their direct marketing purposes and you wish to withdraw that consent to opt-out of such practice and prevent further disclosure of your personal information to third parties for their direct marketing purposes, you may do so by contacting us by postal mail or email at the information provided in the “How to contact us” section above.

European Economic Area

If you are in the European Economic Area, you may have the following rights with respect to your data as set forth in the General Data Protection Regulation (“GDPR”):

The right to request access to your personal information and the following information regarding our use of your personal information:

The purpose of such use
The categories of your personal information that we have used
Who we have disclosed your personal information to

The right to request us to correct any inaccurate personal information concerning you.
The right to request us to erase your personal information when we no longer need such data in connection with our Services.
The right to withdraw consent to our use of personal information, if we are relying on consent to use your personal information.
The right to request us to restrict our use of your personal information (e.g., suspend our use of your personal information).
The right to object to our use of your personal information where we are not using it to perform Services you have requested from us.
The right to receive a copy of your personal information.
The right to lodge a complaint with the supervising authority of your country.

To exercise any of the foregoing rights, please contact us through one of the methods listed in “How to contact us.”

How We safeguard your personal information.

We have put in place appropriate security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. Third parties we engage in our business who may have access to your personal information will only process your personal information on our instructions and they are required to only use your data as necessary to perform their contract with us.

Please note that information communicated over the Internet is never 100% secure. Any transmission of personal information is at your own risk. In case any breach or misuse of your personal information is noticed by us or reported to us, we will report such breach to you, and the concerned authorities for legal action, within 72 hours of receipt of information of such breach.

How long We store your personal information.

We may store your personal information as long as you use our Services to provide you with such Services and for legitimate business purposes.

We may store your personal information following completion of transactions with you to the extent required to comply with our legal, accounting, or reporting requirements and to provide information about our Services (such as your order history) requested by you. Additionally, we may continue to store your personal information contained in our standard back-ups.

After you discontinue using our services, on our own instance, or upon your request, we will delete or de-identify your personal information unless we are legally required or allowed to maintain such personal information.”

Notwithstanding the above, as long as the deletion of the data is prohibited by a legal retention period of two years [2], or any other period defined in any other law applicable for the time being, the data shall only be deleted after expiry of this legal retention period.

Links.

Online Privacy Policy Only

This privacy policy applies only to our online activities and is valid for visitors to our website and regarding information shared and/or collected there.

This policy does not apply to any information collected offline or via channels other than this website.

Our Services may provide links to third-party websites that we do not control. We cannot be held responsible for third parties’ privacy practices or content provided on such websites. If you click on one of these links, please understand that you are leaving our Service and any information you provide will not be covered by this Data Confidentiality Policy.

Minors.

Our Services are not directed to minors under the age of eighteen (18) years. By using our Services, you represent that you are at least eighteen (18) years old. If you do not meet this age requirement, then you must not access or use our Services.

We do not knowingly collect information from children under the age of eighteen (18) years old. If you are under the age of eighteen (18) years old, please do not use our Services and do not provide any information to us.

If you think we have collected information from a child under the age of eighteen (18) through our Services, please contact us through one of the methods listed under “How to contact us” above. If we learn that we have collected the information of a child under the age of eighteen (18) years old, we will take reasonable steps to delete such information.

Special notice regarding data transfers.

We may store your personal information in Singapore or other locations outside your home country. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country.

Governing law and jurisdiction.

This Data Confidentiality Policy shall be construed and governed under the laws of Australia. You agree that venue for all actions, arising out of or relating in any way to your use of our Services, shall be in the courts of competent jurisdiction located in Sydney, Australia, within one (1) year after the claim arises. Each party waives any objections based on forum non convenience and waives any objection to venue of any action instituted hereunder to the extent that an action is brought in the courts identified above.