Bonfyre for Microsoft Teams Privacy Policy 

By accessing or using the Bonfyre for Microsoft Teams application (“App”) and/or any of the products, features or services integrating Bonfyre functionality (collectively, “Services”) offered by Bonfyre Inc., a Delaware corporation (“Bonfyre,” “we,” “us,” “our”) and/or by third parties integrating Bonfyre functionality.  you consent and agree to the following.

GENERAL

“User” or “user”  is any user of the App and/or the Services. “You” or “you” or “your” refers to you, as a User.

Your  “Sponsor” is a commercial customer of Bonfyre and also your employer.

“YOUR INFORMATION” MEANS INFORMATION, CONTENT AND DATA, INCLUDING YOUR PERSONAL INFORMATION, (OTHER THAN ANY WHICH IS AGGREGATED, ANONYMOUS OR DE-IDENTIFIED) WHICH YOU OR YOUR SPONSOR PROVIDE OR IS OTHERWISE COLLECTED OR GENERATED CONCERNING YOU INCLUDING YOUR PERSONAL INFORMATION AS WELL AS ANY SUCH INFORMATION, CONTENT AND DATA YOU SHARE OR ACCESS VIA THE APP OR THE SERVICES).

PURSUANT TO THE PROVISIONS OF AN AGREEMENT REGARDING THE APP AND THE SERVICES (“BONFYRE CUSTOMER AGREEMENT”) BEWEEN BONFYRE AND YOUR SPONSOR,  BONFYRE MAY BE REQUIRED TO FOLLOW THE INSTRUCTIONS OF YOUR SPONSOR WITH REGARD TO YOUR INFORMATION. BONFYRE HAS NO RESPONSIBILITY OR LIABILITY WITH REGARD TO SUCH INSTRUCTIONS OR TO YOUR SPONSOR’S USE, OWNERSHIP, DISPOSITION, DELETION OR OTHER CONDITION WITH REGARD TO YOUR INFORMATION.

IN ADDITION, YOUR RIGHTS WITH RESPECT TO YOUR INFORMATION (INCLUDING RIGHTS OF ACCESS, REVIEW, CHANGE AND DELETION AND OTHER RIGHTS) ARE SUBJECT TO, AND EXERCISABLE ONLY THROUGH, YOUR SPONSOR AND IN COMPLIANCE WITH YOUR SPONSOR’S POLICIES (INCLUDING THOSE WITH RESPECT TO DATA SECURITY AND PRIVACY COMPLIANCE), REQUIREMENTS, STANDARDS AND PROCEDURES (COLLECTIVELY, “YOUR SPONSOR’S POLICIES”). BONFYRE IS NOT RESPONSIBLE FOR YOUR SPONSOR’S POLICIES OR FOR YOUR SPONSOR’S COMPLIANCE WITH THEM.

COLLECTION

General

We receive and store information, including Personal Information that you, your Sponsor or others may provide us.  “Personal Information” is defined as any information collected and stored under your name or that could be used to identify you but does not include any such information which has been aggregated, de-identified or otherwise anonymized. In addition, we receive and store log data, device information (including device type, operating system, device settings, unique device identifiers and crash data) and usage data and use information regarding use of the App and/or the Services. This information helps us provide the App  and/or the Services and may also be used for various internal purposes (such as development and improving the App  and/or the Services).

 

Location Data

We do not currently collect location information. In the event that in the future we collect location information, then if you have chosen to enable location services, we would automatically receive your location when you use the Services. In the event that, in the future, we collect location information this information helps us provide the Sites and/or the Services and may also be used for various internal purposes (such as development and improving the Sites and/or the Services).

 

Aggregate Data

We track aggregate statistics internally across particular user groups and across larger groupings of users. These statistics sometimes include personal information to indicate unique users and usage. These statistics sometimes include Personal Information such as your device’s unique identification number (“UDID”) to indicate unique users and usage. This information helps us track and analyze usage and performance of the Sites and/or the Services.

We may (and may also work with third parties to) collect, compile, generate and create aggregated, anonymous and/or de-identified content, information and data (“NPID“), perform statistical and other analyses of this NPID and user behavior and create compilations and other works. We own all NPID, the results of all such analyses and all such compilations and other works (“NPID assets”).

 

Sponsor Provided Data

Your  Sponsor may provide Bonfyre with information (including Personal Information) with regard to you. We use such information for purposes of providing the App and associated Services pursuant to our contract with your Sponsor and as otherwise required by the Sponsor. Your  Sponsor is solely responsible for providing such information and for the use thereof.

Personal Information

During the past twelve months we have collected the following categories of Personal Information from users:

 

Category	Examples	Collected	Notes
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES	Bonfyre does NOT collect Social Security, Driver’s license, or Passport numbers
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES	Bonfyre collects the name and email address only. In some cases, Sponsors of a Sponsored Bonfyre Community or Sponsored Bonfyre Service  may provide Bonfyre  the telephone number or employee identification number
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES	We collect usage information only in regards to the App and Services
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES	Only as provided by the Sponsor of your use of the App and the Services
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

 

The categories of Personal Information listed as “Collected” above were obtained by us as described herein. In the preceding twelve (12) months, we have disclosed such Personal Information: (i) to  (or pursuant to our agreements with) the applicable Sponsors and (ii) as contemplated above under “STORAGE”, “AGGREGATE DATA” and “THIRD PARTY SERVICE PROVIDERS” but  have  not otherwise disclosed Personal Information  for a “business purpose” (as defined in the CCPA) or  sold Personal Information.

 

USE

 

General

We may use information and data (includingYour  Information) to communicate with, and send information or Content (defined below) to,  you and  other Users and  Sponsors, to provide the App and the Services (including existing and proposed features) and otherwise to perform our agreements with Sponsors. We may also use such information and data for various internal purposes (such as product development and improvements). Your Sponsor may utilize such information and data to contact you and/or to send you information and Content. The Sponsor is solely responsible for them and for any information (including Personal Information) they provide and for the use thereof.

Third Party Providers

We may employ third party service providers in connection with providing the App and the Services and/or with making (or maintaining) the functionality, reliability and/or availability thereof and may share information and data (including Your Information) with them. In addition, Sponsors may employ, and direct that information and data (including Your Information) be shared with, third party service providers to the Sponsor. We have no responsibility with regard to any third party service provider or to any use by them of any information and data (including Your Information) which may be shared with them.

 

Sponsors

Your rights with respect to Your Information (including rights of access, review, change and deletion and other rights) are subject to, and exercisable only through, your Sponsor and in compliance with the Your Sponsor’s Policies (including those with respect to data security and privacy compliance). Your Sponsor may be deemed to own Your Information. Bonfyre is not responsible for Your Sponsor’s Policies or for your Sponsor’s compliance therewith. Bonfyre shall follow the lawful instructions of our Sponsor  with regard to the use, processing, deletion, access and change with regard to Your Information (and, if it cannot (or is unwilling to) provide such compliance for whatever reasons, Bonfyre agrees to inform Your Sponsor promptly, in which case our Sponsor may suspend or terminate the processing (and require the deletion by Bonfyre from its systems) of Your Information.

Sponsors are solely responsible for their use of any Content, data and information (including Your Information) and for complying with applicable law pertaining thereto. Your Sponsor may have access (and may allow or direct others to have access) to your information and to other user specific data and may employ, and direct that data (including your information) be shared with, third party service providers designated by your Sponsor. The foregoing is subject only to Your Sponsor’s Policies.

Security

We take reasonable and appropriate precautions to protect your Personal Information. However, no data on the Internet or on a network is completely secure, so we cannot guarantee the security of your data (including your Personal Information). We are not responsible for any loss of data or the consequences thereof. In the event that we believe the security of your data in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, or in the event that we are required by law to inform you of any unauthorized access to your Personal Information, we may choose to notify you electronically, in writing, by email, push notification, by telephone or otherwise at our sole discretion.

Storage

Bonfyre’s data and information (including personal information) is stored on Amazon Web Services servers located in the United States. Bonfyre makes no guaranty of, and will not be liable for, security, confidentiality or privacy of your information (including your personal information) or of any communication or information transmitted on the App or the Services. We are not responsible for any loss of your information or the consequences thereof.

If you are a California resident and the CCPA is applicable, you have the right to request disclosure to you of certain information about our collection and use of your personal information over the past 12 months. To exercise the right, please submit a verifiable consumer request directly to your Sponsor. The procedures for you to change or delete any of your personal information will be subject to your Sponsor’s policies.

 

RIGHTS OF ACCESS, REVIEW, CHANGE AND DELETION

If you are a California resident and the CCPA is applicable to Bonfyre, you have the right to request that we disclose to you certain information about our collection and use of your Personal Information over the past 12 months. The procedures for you to change or delete any of your Personal Information will be subject to the polices of the applicable Sponsor and, as noted above, are solely the Sponsor’s responsibility. We encourage you to familiarize yourself with your Sponsor’s policies with regard to Content, information, data (including Personal Information) and privacy.

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. In response to your request, we may elect to make the personal information invisible to other users and the public (rather than deleting it entirely), in which case the personal information may remain on servers we control and/or may be publicly available elsewhere if a third party copied and reposted the personal information. In addition, we retain Personal Information in order to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law. Your above rights are subject to the policies of your Sponsor and are solely your Sponsor’s responsibility. We encourage you to familiarize yourself with your Sponsor’s policies with regard to Content, information, data (including Personal Information) and privacy.

To exercise the rights described above, please submit a verifiable consumer request directly to your Sponsor. You may only make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

TERMINATION

Bonfyre reserves the right to immediately terminate (and Bonfyre shall, at the request of Your Sponsor, immediately terminate) your access to all or any part of the App or the Services at any time, with or without cause or notice. On termination, we may (and shall at the direction of Your Sponsor) delete Your Information, although we may elect to make Your Information invisible to other users and the public (rather than deleting it entirely). In addition, we may retain Your Information in order to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations and take other actions otherwise permitted by law. Your Information  will be subject to Your Sponsor’s Policies. NPID and NPID assets will be unaffected and continue owned by us.

 

MISCELLANEOUS

 

If you are a California resident and if the CCPA applies to Bonfyre, California law may provide you with additional rights regarding our use of your “personal information”. We will not discriminate against you for exercising your rights under the CCPA.

 

If you are a California resident and if the CCPA applies to Bonfyre, California law may provide you with additional rights regarding our use of your “personal information”. We will not discriminate against you for exercising your rights under the CCPA.

We may make changes to this Privacy Policy for a variety of reasons. The current Privacy Policy is available at https://bonfyreapp.com/privacy-policy-teams. Your access or use of the App or Services following the posting of any changes constitutes acceptance of those changes.

If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of assets or similar transaction or proceeding, a transfer of information described in this Privacy Policy may occur.

 

For questions about this Privacy Policy, please contact us at support@bonfyreapp.com. Complaints by a user with regard to violations by Bonfyre of this Privacy Policy may be directed to us at support@bonfyreapp.com or to any applicable regulatory authority having jurisdiction.

This Privacy Policy is governed by the internal laws of the State of Missouri and you submit to the exclusive jurisdiction of any Missouri state of US federal court sitting in St. Louis County MO over any dispute, agree to accept service of process by mail, and waive any jurisdictional or venue defenses. A printed version of this Privacy Policy shall be admissible.

If you are a user located in the European Economic Area (“EEA”), Our legal basis for collecting and using the personal information normally is (i) your consent, (ii) our contract with  your Sponsor or (iii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you (or from your Sponsor).Bonfyre’s Data Protection Officer can be contacted at support@bonfyreapp.com.  As noted above inquiries with regard to your Privacy and other rights with regard to your data should be addressed directly to your Sponsor and your Sponsor’s data protection officer.

 

The categories of Personal Information listed as “Collected” above were obtained by us as described herein. In the preceding twelve (12) months, we have disclosed such Personal Information: (i) to  (or pursuant to our agreements with) the applicable Sponsors and (ii) as contemplated above under “STORAGE”, “AGGREGATE DATA” and “THIRD PARTY SERVICE PROVIDERS” but  have  not otherwise disclosed Personal Information  for a “business purpose” (as defined in the CCPA) or  sold Personal Information.

 

USE

General

We use information and data to communicate with Sponsors, to provide the App and the Services and otherwise to perform our agreements with Sponsors. We may also use such information and data for various internal purposes (such as product development and improvements).

Third Party Providers

We may employ third party service providers in connection with providing the App and the Services and/or with making (or maintaining) the functionality, reliability and/or availability thereof and may share your information (including personal information) with them.

Sponsors

Your Sponsor may have access (and may allow or direct others to have access) to your information and to other user specific data and may employ, and direct that data (including your information) be shared with, third party service providers designated by your Sponsor. The foregoing is subject only to your Sponsor’s policies.

Security

We take reasonable and appropriate precautions to protect your Personal Information. However, no data on the Internet or on a network is completely secure, so we cannot guarantee the security of your data (including your Personal Information). We are not responsible for any loss of data or the consequences thereof. In the event that we believe the security of your data in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, or in the event that we are required by law to inform you of any unauthorized access to your Personal Information, we may choose to notify you electronically, in writing, by email, push notification, by telephone or otherwise at our sole discretion.

Storage

Bonfyre’s data and information (including personal information) is stored on Amazon Web Services servers located in the United States. Bonfyre makes no guaranty of, and will not be liable for, security, confidentiality or privacy of your information (including your personal information) or of any communication or information transmitted on the App or the Services. We are not responsible for any loss of your information or the consequences thereof.

If you are a California resident and the CCPA is applicable, you have the right to request disclosure to you of certain information about our collection and use of your personal information over the past 12 months. To exercise the right, please submit a verifiable consumer request directly to your Sponsor. The procedures for you to change or delete any of your personal information will be subject to your Sponsor’s policies.

TERMINATION

Your license and right of access and use of the App and the Services may be terminated by your Sponsor pursuant to your Sponsor’s Policies or by us if there is a violation the provisions hereof or of the provisions of the contract between Bonfyre and your Sponsor or of Terms of Use (https://bonfyreapp.com/terms-of-use-teams) and will terminate automatically on the expiry of our underling contract with the Sponsor. On termination, your Personal Information will be deleted on direction from your Sponsor, although we may elect to make your personal information invisible to other users and the public (rather than deleting it entirely). In addition, we may retain Personal Information in order to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations and take other actions otherwise permitted by law. Your information (other than personal information) will be subject to your Sponsor’s policies. NPID and NPID assets will be unaffected and continue owned by us.

 

MISCELLANEOUS

We may make changes to this Privacy Policy for a variety of reasons. The current Privacy Policy is available at https://bonfyreapp.com/privacy-policy-teams/. Your access or use of the App or Services following the posting of any changes constitutes acceptance of those changes.

If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of assets or similar transaction or proceeding, a transfer of information described in this Privacy Policy may occur.

For questions about this Privacy Policy, please contact us at support@bonfyreapp.com. Complaints by a user with regard to violations by Bonfyre of this Privacy Policy may be directed to us at support@bonfyreapp.com or to any applicable regulatory authority having jurisdiction.

This is governed by the internal laws of the State of Missouri and you submit to the exclusive jurisdiction of any Missouri state of US federal court sitting in St. Louis County MO over any dispute, agree to accept service of process by mail, and waive any jurisdictional or venue defenses. A printed version of this Privacy Policy shall be admissible.

If you are a user located in the European Economic Area (“EEA”), Our legal basis for collecting and using the personal information normally is (i) your consent, (ii) our contract with  your Sponsor or (iii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you (or from your Sponsor).Bonfyre’s Data Protection Officer can be contacted at support@bonfyreapp.com.  As noted above inquiries with regard to your Privacy and other rights with regard to your data should be addressed directly to your Sponsor and your Sponsor’s data protection officer.