BuildWitt Connect
Privacy Policy

When you open an account with us through the Services (“Account”), we may ask you to provide us with identifiers and contact information such as your name, email address, and any other information you may provide. Some of this information may be considered “personally identifiable information” (“PII”) or “personal information” (“PI”), meaning it reasonably identifies you or your device or could reasonably be linked or associated with you. We may also collect identifiers when you participate in any interactive features of the Services (like send us a message through the Services), fill out a form, publish statements on our platform, participate in a contest or promotion, make a purchase, apply for a job, communicate with us via third-party social media sites, request customer support, or otherwise communicate with us.

When you pay for our Services, we ask for your credit card information. Your credit card is passed directly to our payment processor. We do not store this information on our servers. We do store a record of the payment transaction, including the last 4 digits of the credit card number, for account history, invoicing, and billing support. We also store your billing address to calculate any sales tax due in the United States, to maintain records that may be used for investigations of potentially fraudulent credit card transactions, and to print on your invoices. We may collect commercial information such as your purchase history, including records of products or services you have purchased, provided, returned, or are considering purchasing from us.

Finally, we may collect other content and information you share through the Services when you submit information or content, such as by commenting on a blog or participating in online communities, or when you otherwise interact with our Services. When you interact with other users, our customers, their admins and their online communities on our Site, App or Services, they may collect any content or information you share with them. Circle may also collect any content or information you share with others through the Site, App or Services.

When you access or use the Site, App, or Services or transact business with us, we and our third-party partners may automatically collect information you provide to us, information about how you access and use the Services and information about the device you use to access the Services, including:

• Device Identifiers: Identifiers, such as your IP address, Internet service provider (“ISP”), the type of mobile device you use, the temporary or persistent unique device identifiers (sometimes called UDID), and identifiers associated with browser cookies, web beacons and similar technologies we deploy on our Site, App, or Services;
• Internet or Other Electronic Network Activity Information: We and our third-party partners may collect information about the devices and computers you use to access our Services, such as browser type, language, operating system, the referring web page, pages visited, and hyperlinks clicked. When you use our Services, we may collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Site, App, or Services and other information about your internet activity (“Usage Information”), including the pages you visit, the links you click, the ads you view and click on, videos you watch, purchase information and your checkout process, your location when you access or interact with our Services, and other similar actions. We may also use third-party tools to collect Usage Information you provide to us or information about how you use the Service and may record your mouse movements, scrolling, clicks and keystroke activity on the Service and other browsing, search or purchasing behavior. These tools may also record Usage Information you enter when you interact with our Services or engage in chat features through our Services.
• Commercial Information such as your purchase history, including records of products you have purchased or are considering purchasing from us, services you have provided or have had provided to you, such as transactional information when you make a purchase, we collect information about the transaction, such as services provided, product details, purchase price, and date and location of the transaction.
• Geolocation Information. We may derive the approximate location of your device from your IP address. We may combine this information with other location-based information, such as your billing or postal code. You have the ability to stop the collection of precise location information at any time (see “Your Choices” below for details).
  
  We (and our third-party partners and service providers) use different technologies to collect information, including cookies, embedded scripts, mobile SDKs, location-identifying technologies and web beacons. For reference, cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits and web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy. Additional information about cookies may be found at: https://support.microsoft.com/en-us/help/260971/description-of-cookie

We may also obtain information about you from other sources. For example, we may collect information about you from third parties, including but not limited to mailing list providers and publicly available sources. When you interact with BuilldWitt Connect, online communities and other users on our Site, App or Services, we may collect from them any content or information you choose to share or provide. We may also obtain information about you from other sources, including but not limited to social media platforms, marketing partners, and other third parties. For example, if you connect your social media account to your Account or create or log into your Account through a social media site, certain information from your social media account will be shared with us, which may include information that is part of your profile or your friends’ profiles. In addition, we may supplement the information that you provide us and/or the information we collect from you with demographic, social, and other information about you that we receive from other sources. Additional third parties may include but are not limited to Google, LinkedIn, Meta, Warmly, Hotjar, ZoomInfo, HubSpot, Mailchimp, and Stripe. Once we combine information from other sources with your information collected pursuant to this policy, we apply this policy to the combined information as long as it is combined.

If BuildWitt Connect obtains information from third-party sources, BuildWitt Connect takes commercially reasonable measures to ensure the third parties lawfully obtained and provided the information to us.  If the third parties unlawfully obtained and/or provided the information to us despite our reasonable measures to ensure the third parties complied with all legal requirements in obtaining and providing the information to us, you understand, agree, and acknowledge that your sole legal remedy is against the third party that engaged in the unlawful activity and that you will not assert any cause of action, claim or demand against us.

To enhance security and promote operational efficiency, the Site utilizes the resources of reputable hosting facilities that are controlled by third parties.  BuildWitt Connect is unable to provide any guarantees or warranties about these third parties’ retention or usage of your information.

We use the information we collect about you for a variety of business and commercial purposes, including, but not limited to:

• provide, maintain, and improve the Site, App, or Services and to enhance and personalize your experience;
• process, complete, and maintain records on transactions;
• provide our users and the online communities with the Site, App or Services. Other users may use your personal information for their own purposes, such as to provide you with content, discussions, events and memberships;
• send you technical notices, updates, security alerts, and support and administrative messages;
• respond to your comments, questions, and requests, and to provide customer service;
• communicate with you about products, services, offers, promotions, rewards, and events offered by BuildWitt and others, and provide news and information we think will be of interest to you;
• monitor and analyze trends, usage, effectiveness and activities in connection with our Site, App, or Services, including our offers, advertising, communications features, and customer service;
• detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of BuildWitt Connect;
• facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
• link or combine with information we get from our Site, App, or Services and from others to help understand your needs and provide you with better service;
• maintain appropriate records for internal administrative purposes;
• carry out any other purpose described to you at the time the information was collected or permitted by law.

Notice about Social Security Numbers. We do not collect social security numbers of customers or other users, and you should not provide such information to BuildWitt Connect. Nonetheless, if BuildWitt Connect comes into possession of users’ social security numbers or collects such information in the future, the information will be treated confidentially and not shared with third parties unless allowed by law.  Additionally, BuildWitt Connect will take reasonable steps to limit the access to such social security numbers and take legally required steps to secure the transmission of the data containing such social security numbers.

We may share information about you, including personal information, for any legally permissible purpose. We may match, use, and share any of the information we collect from you to any personally identifiable information we obtain through third parties.  Examples of some ways we may use or share information that we collect about you include:

• With Service Providers. We may disclose your information to vendors, consultants and other service providers under contract who help with our business operations or who we provide services to (such as web hosting and operations of the App, IT, to process opt-out requests, to assist us in responding to consumer requests for access, deletion, or correction of information, direct mail and email distribution, site analytics, operations or legal and compliance services, and customers purchasing services from BuildWitt Connect). 
• With Data Analytics and Aggregation Vendors. We may share aggregated information that does not include your PII or PI, and we may otherwise disclose non-identifying information such as general (non-specific) geographic location, device/browser technology, onsite behavior, population data, user segmentation, survey results, and log data, with third parties for data analysis, demographic profiling, and other purposes. Any aggregated information shared in this manner will not contain your personal information.
• With Other Users of the Site, App, or Services. If you provide or share information with other users on the Site, App or Services, they may use it for their own purposes. If you post information or content, such as by posting photos, commenting on a blog, or participating in online communities, or when you interact with the Site, App, or Services through social media sites, plug-ins or other applications, depending upon your privacy settings, this information may become public on the Internet. We cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.
• With Legal and Law Enforcement. From time to time, BuildWitt Connect may be required to respond to a subpoena, a court order or similar investigative demand from law enforcement, a government agency, or a private litigant.  BuildWitt Connect reserves all rights to defend, within its sole discretion, against such legal requests, demands, and claims.  For instance, BuildWitt Connect may raise or waive legal objections or rights.  BuildWitt Connect also reserves the right to disclose your information, as allowed by applicable law, when we believe it is reasonably appropriate based on the situation.  Such disclosure may occur, but is not limited to, disclosing your information in connection with efforts to:  (i) investigate, prevent, or commence other actions regarding suspected illegal activity or other wrongdoing; (ii) protect or defend the rights, property or safety of our company, our users, our employees, or others; (iii) comply with applicable law or cooperate with law enforcement; or (iv) enforce the TOU or other agreements or policies related to the Site, App, or Services.
• In Connection with a Change of Control. We may transfer or disclose 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 by another company.
• With your Consent. Where applicable, we may share your information with your consent or at your specific direction.
• For Marketing and Advertising. You agree that any testimonial feedback or other comments provided by you to BuildWitt Connect becomes the sole and exclusive property of BuildWitt Connect and that such information may be used by BuildWitt Connect for any legally permissible purpose, including but not limited to marketing and advertising its services and products.

Third Party Privacy Policies May Be Applicable. This Privacy Policy does not cover any third party’s use or handling of your information once it is shared.  Instead, the privacy policies of the third party(ies) will govern.  We encourage you to visit the websites of those third parties and fully read and understand their privacy policies.  Some of these entities or their servers may be located outside the United States.

Your Information Will Not Be Sold. We will not sell any information you submit to us to any third party without prior written notice to you and an opportunity for you to opt-out of such sale, provided, however, you agree that we are able to sell aggregated and/or deidentified information that we may collect related to you and your use of the Site.

As outlined in the TOU, the Site, App, and Services is for adult use only. The Site, App, and Services are meant for adults and those who have reached the age of majority as defined by the laws of their domicile.  The Site, App, and Services are not meant for individuals under the age of eighteen (18) or those defined by the laws of their domicile as minors.  Nonetheless, this Privacy Policy is still designed to comply with the Children’s Online Privacy Protection Act (“COPPA”) to the extent COPPA applies.  Accordingly, we do not knowingly collect or retain any personal information about users under the age of thirteen (13).  If we obtain actual knowledge that we collected or retained personal information about a child under the age of thirteen (13), that information will be promptly deleted from our database, servers, and all other media.  Since we do not collect information from users under thirteen (13) years old, no such information is disclosed to third parties.  If you believe we might have any information from or about an individual under 18, please contact us at the email address below.

The Site, App, or Services may offer social sharing features and other integrated tools, which let you share actions you take on our Site, App, or Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Our Site, App, or Services may contain links to other websites, including our affiliated or co-branded web sites. Other websites may also reference or link to our Site, App, or Services. These other websites may not be controlled by us. BuildWitt Connect disclaims any responsibility for the privacy practices of third parties that may have links to or from our website, or any framed content on our website.  We encourage our users to read the privacy policies of every website or mobile application that collects PII or PI. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of other websites or mobile applications. Visiting these other websites is at your own risk.

We may allow third-party partners and tools to provide analytics services and serve advertisements on our behalf across the Internet and in the Site, App, or Services. These partners may automatically collect Device Identifiers and Usage Information through technologies such as cookies and web beacons, including mouse clicks and movements, page scrolling and any text keyed into website forms and other browsing, search or purchasing behavior. These tools may also record information you enter when you interact with our Services and other websites and applications. This information may be used by BuildWitt Connect and our third-party partners to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Site, App, or Services, and better understand your online activity. Please see our Cookie Policy for more information about these practices and any choices you may have regarding cookies.

We participate in interest-based advertising and use third-party advertising partners to serve you targeted advertisements based on your browsing history. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar technologies. We may share a common account identifier (such as an email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at http://www.aboutads.info/choices.

BuildWitt Connect is based in the United States and we may process and store information in the U.S. and other countries. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

• Account Information. You may update and correct certain Account information you provide to us at any time by logging into your Account. If you wish to delete or deactivate your Account, you may email us at privacy@buildwitt.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
• Location Information. If you initially consent to our collection of this location information through the Site, App, or Services, you can subsequently stop the collection of this information at any time by changing the preferences on your computer or device. If you do so, certain features may no longer function properly.
• Cookies. For more information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to cookies, please see our Cookie Policy.
• Communications with BuildWitt Connect. We want to communicate with you in ways you want to hear from us. Examples include email, which may contain special offers and new product announcements. To the extent that you are receiving marketing communications from the Site, App, or Services you may unsubscribe or opt-out of future communications as follows:
  
  
  • If you no longer wish to receive emails you may click on the hyperlink titled “Unsubscribe” at the bottom of any marketing related email BuildWitt sends to you, and then follow the directions to unsubscribe from email
  • You can modify your preferences in your Account settings. Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your account or purchases
  • You may opt out and/or unsubscribe to communications from BuildWitt at any time at: https://www.buildwitt.com/legal/privacy-optout
    
    
• Mobile Push Notifications/Alerts. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device. By downloading and using our App, you may also receive promotional messages, offers, news and information about BuildWitt. If you do not want to receive “in app” messages, offers, news and information, do not download or use our App.
• Visitors Outside the United States. This Privacy Policy is intended to cover collection of information on the Site, App, or Services from residents of the United States. The laws in other countries may or may not be as comprehensive as those in the United States.  If you are a resident of another country and/or are visiting the Site, App, or Services from outside the United States, you acknowledge and agree that your information may be transferred to, stored, and processed in the United States where our servers are located, and our central database is operated.  You also acknowledge that your use of the Site, App, or Services shall be governed exclusively by the laws of Tennessee and as if all transactions with us or otherwise through the Site, App, or Services take place within Tennessee.  By using the Site, App, or Services, you acknowledge and agree that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.  If you are unwilling to accept these terms, then you agree that you will not use or access the Site, App, or Services or our services.
• Additional Notice to Nevada Residents. If you are a Nevada resident, you may opt-out of the sale of your personal information.  To do so, please contact us at privacy@buildwitt.com and title the subject of your email “Nevada Privacy Rights Opt-Out Request”.  In response, we will request information from you to verify your identity.  We will attempt to respond to your request, once verified, within sixty (60) calendar days.
• SUPPLEMENTAL PRIVACY POLICY APPLICABLE TO CALIFORNIA RESIDENTS ONLY.
  We will not share any personal information about you with other companies if prohibited by applicable California law or to the extent your prior consent to share is required by applicable California law. California residents may, no more than once per calendar year, request information about our disclosures of certain categories of personal information to third parties for direct marketing purposes. To be valid, requests must be submitted to us at privacy@buildwitt.com and have “California resident information request” written in the “subject” line of the e-mail. Within thirty (30) days of receiving this request, we will provide a list of the categories of personal information disclosed for direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of the third parties.  
• Supplemental Privacy Policy. In addition to the foregoing, if you are a resident of California, Colorado, Connecticut, Virginia, or Utah, the Supplemental Privacy Policy (https://www.buildwitt.com/legal/privacy-policy-supplement-buildwitt-connect) applies to you and is incorporated herein by reference. By using the Site, you acknowledge that you have read and understand the Privacy Policy and Supplemental Privacy Policy.  The Supplemental Privacy Policy has been adopted to comply with the California Consumer Privacy Act of 2018 (“CCPA”), Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), Virginia Consumer Data Protection Act (“VCDPA”), and Utah Consumer Privacy Act (“UCPA”) and any terms defined in the CCPA, CPA, CTDPA, VCDPA, or UCPA have the same meaning when used in the Supplement.

In some states, users may be entitled to know how we respond to “Do Not Track” browser settings.  There is little consensus in the industry about what “Do Not Track” means; however, we recognize “Do Not Track” signals as an opt-out for the sharing of your data with third parties.  We take good faith efforts to comply with any “Do Not Track” request; however, you may still need to contact any third-party companies (including those who may have cookies or beacons on the Site) to direct them to not share your data with third parties. To learn more or opt-out from data collection by third-party companies you can visit:  http://www.networkadvertising.org/choices  or www.aboutads.info/choices/

We value our users’ privacy and provide them with the option to “opt-out” of having their information used for purposes not directly related to the Site.  If you wish to change your opt-out preference or update your information after you initially sign up for your account, you can opt-out by any of the following means:

1. Send a written request to:
   BuildWitt Connect
   1400 Adams ST STE 202
   Nashville, TN 37208; or
   
   
2. E-mail: opt-out@buildwitt.com

Your request will generally be responded to within three (3) business days if your request is via e-mail, or thirty (30) days after receipt if your request is via United States mail.

Please note that changing your opt-out preference will only affect future activities or communications from us.  In other words, if we already provided your information to a third party before you changed your opt-out preferences, you will need to contact the third party directly.  To opt-out of communications from our third-party business partners, if any, please contact them directly.  Additionally, opting-out will only remove you from the BuildWitt Connect service.  If you have other products or services with BuildWitt, there may be a separate Privacy Policy that applies to that product or service, and you will need to separately opt-out of that product/service.

NOTE: If you choose to opt-out, the Site, App or Services may not work as you intend.

We retain personal information only for as long as is reasonably necessary to fulfill the purpose for which it was collected. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

This Privacy Policy may be updated from time to time.  We reserve the right to modify this Privacy Policy at any time without notice, so please review this Privacy Policy frequently.  When changes are made to this Privacy Policy, we will revise the “last updated” date at the top of this Privacy Policy.  If we make any material changes in the way we collect, use, and/or share your personal information, we will also post notice of the changes on the Site and/or may notify you by sending an e-mail to the e-mail address you most recently provided us under your account.  Your continued use of the Site or any Services after we have posted any Privacy Policy changes indicates your agreement to such changes unless you notify us otherwise.

If you wish to retain a copy of this Privacy Policy, you should print a copy for your records.

If any terms of this Privacy Policy are held invalid and/or unenforceable by a court of law or a competent jurisdiction, the remaining provisions of this Privacy Policy shall remain in full force and effect.

The adoption or publication of this Privacy Policy does not subject BuildWitt Connect to any stricter duty in its collection, handling, storage and disclosure of nonpublic information than otherwise applies to BuildWitt Connect under applicable law.  No person or entity shall have any right or recourse against BuildWitt Connect nor any of its affiliates, agents, sponsors, or other related parties based on any alleged violation of or noncompliance with this Privacy Policy.

In certain situations, customers of BuildWitt Connect may dictate how their personal information is used, stored, and processed.  If you are a customer, you may provide written instructions to BuildWitt Connect about how you wish for your personal information to be treated.

General Contact:
BuildWitt Media Group, LLC
1400 ADAMS ST STE 202
NASHVILLE, TN 37208
(615) 200-8303
PRIVACY@BUILDWITT.COM