PRIVACY POLICY

INTRODUCTION....................................................................................................................1

WHAT INFORMATION DO WE COLLECT? ...........................................................................2

Personal information you disclose to us ...........................................................................2 a

Information automatically collected ..................................................................................2 b

Information collected from other Sources .........................................................................2 c

HOW DO WE USE YOUR INFORMATION? ...........................................................................3

WILL YOUR INFORMATION BE SHARED WITH ANYONE? .................................................4

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? ....................................5

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY? ........................................6

WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES? ....................................................7

HOW LONG DO WE KEEP YOUR INFORMATION? ..............................................................8

HOW DO WE KEEP YOUR INFORMATION SAFE? ..............................................................9

DO WE COLLECT INFORMATION FROM MINORS? ...........................................................10

WHAT ARE YOUR PRIVACY RIGHTS? ................................................................................11

Account Information ..........................................................................................................11 a

TERMS AND CONDITIONS .................................................................................................12

DO WE MAKE UPDATES TO THIS POLICY? ......................................................................13

HOW CAN YOU CONTACT US ABOUT THIS POLICY? ......................................................14

In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data.

We collect personal information that you voluntarily provide to us when registering at the Sites or Apps expressing an interest in obtaining information about us or our products and services, or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we collect can include the following:

1. Name and Contact Data. We may collect your first and last name, email address, postal address, phone number, and other similar contact data.
2. Credentials. We may collect passwords, password hints, and similar security information used for authentication and account access.
3. Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our websites.

We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookies Policy.

Information collected from other Sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).

HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To send administrative information to you for Business Purposes, Legal Reasons and/or possibly Contractual. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.


• To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" below).


• Fulfil and manage your service requirements for Contractual purposes. We may use your information to fulfil and manage your service requirements, payments, and other related matters as made through the Sites.


• To post testimonials with your Consent. We post testimonials on our Sites that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at support@bcoperationsservices.com and be sure to include your name, testimonial location, and contact information.


• Deliver targeted advertising to you for our Business Purposes and/or with your Consent. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For more information, see our Cookie Policy


• Request Feedback for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of our Sites.


• To protect our Sites for Business Purposes and/or Legal Reasons. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention.


• To enable user-to-user communications with your consent. We may use your information in order to enable user-to-user communications with each user's consent.


• To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and/or possibly Contractual.


• To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.


• For other Business Purposes We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.

We only share and disclose your information in the following situations:

• Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).


• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.


• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.


• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.


• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Sites. These companies may use information about your visits to our Site and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookie Policy for further information.


• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.


• Business Partners We may share your information with our business partners to offer you certain products, services or promotions.


• With your Consent. We may disclose your personal information for any other purpose with your consent.


• Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Sites) or otherwise interact with public areas of the Site, such personal information may be viewed by all users and may be publicly distributed outside the Site in perpetuity.

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Antigua and Barbuda. If you are accessing our Sites from outside Antigua and Barbuda, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information.

European Commission's Standard Contractual Clauses. We implement such measures to effect the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers, which require all such recipients to protect personal information that they process from the European Economic Area (hereinafter “EEA”) in accordance with European data protection laws. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.

The Sites may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites. You should review the policies of such third parties and contact them directly to respond to your questions.

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). Subject to the foregoing, no purpose in this policy will require us keeping your personal information for any longer than 2 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from children under 18 years of age. By using the Sites, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at support@bcoperationsservices.com.

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions like the European Economic Area, you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please contact us at support@bcoperationsservices.com. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisor authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

You may at any time review or change the information in your account or terminate your services with us by emailing us your request accompanied with a copy of your identity card to the address to initiate this process. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising by advertisers on our Site visit https://optout.aboutads.info/.For further information, please see our Cookie Policy.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by:

• Noting your preferences at the time you register your account with the Sites.
• Logging into your account settings and updating your preferences.
• Contacting us using the contact information provided below

By using this Site, you undertake to comply with and accept the following terms of use. The company owns the exclusive copyright and intellectual rights of the Site, its design and its entire content. Use of this Site, or parts thereof, in any form whatsoever, is prohibited without the prior written consent of the company.

The contents of this Site, including brands, logos, drawings, data, product and company names, texts, images, etc., are protected by intellectual rights and belong to the company and/or entitled third parties.

The information provided on and via this website may not be saved (other than as necessary to view the website), reproduced, modified, made public, distributed or send, sold or transferred in any other way, nor may any rights to this information be granted to third parties.

The information on the Site is of a general nature. The information is not adapted to personal or specific circumstances and can therefore never be considered as personal, professional or legal advice to the user. The website may contain hyperlinks to third-party websites or pages or refer to them indirectly. The publication of links to these websites or pages in no way implies an implicit approval of their contents.

The company expressly declares that it has no control over the content or other characteristics of these websites and can under no circumstances be held liable for their contents or characteristics or any other form of damage resulting from their use.

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, email us at legal@bcoperationsservices.com or by post to:

BC Operations Services Limited

FAO: Privacy Officer

Starling Business Centre

Units 6-10, Factory Road

St. John’s,

Antigua and Barbuda

If you are a resident in the European Economic Area, the "data controller" of your personal information is BC Operations Services. The company sometimes gains access to the customers personal data in the context of the services it provides on behalf of the customer. In these situations, the customer will act as controller and the company will act as the data processor. The company when acting as the data processor will process the data on behalf of the customer according to the instructions of the customer and/ or in accordance with the GDPR.

If you have any further questions or comments about us or our policies, email us at legal@bcoperationsservices.com or contact us by post at:

Starling Business Centre

Units 6-10, Factory Road

St. John’s,

Antigua and Barbuda