Last Modified on: August 8th, 2020

Bossa Nova Data Solutions LLC and The Caperio software platform collect your personal information through this website, social media, email and apps as described below.For more detailed information please see below.

Bossa Nova Data Solutions LLC and The Caperio software platform value your privacy. This Privacy Policy describes our practices in connection with information that we collect:

• Through websites operated by us from which you are accessing this Privacy Policy (the “Sites”);
• through the software applications made available by us for use on or through computers and mobile devices (the “Apps”);
• through our social media pages and apps (collectively, our “Social Media Pages”);
• through HTML-formatted email messages that we send to you that link to this Privacy Policy.
• Any offline business interactions you may have with us.

Collectively, we refer to the Sites, the Apps and our Social Media Pages, these emails and offline business interactions as the “Services”). 

Personal and Other Information We May Collect

“Personal Information” is data and information that can identify you as an individual or relates to an individual, either alone or when combined with other information. The categories of  Personal Information we collect include:

• Identifiers such as name and contact Information;
• Personal information, such as credit or debit card number information

If you submit any Personal Information relating to other people to us or to our service providers in connection with the Sites, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services:  We collect Personal Information through the Services, for example, when you sign up for a newsletter, download a publication, register for an event, request access to an available online demonstration, or request information.
• Offline:  We collect Personal Information from you offline, e.g., when you attend an event.
• From Other Sources:  We receive your Personal Information from other sources, for example:
• publicly available databases
• joint marketing partners, when they share the information with us
• sales channel partners
• demand generation companies;

We need to collect Personal Information in order to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. Other information we may collect include:

• Browser and device information;
• Information collected through audit logs, cookies, pixel tags, and other technologies;
• Demographic information and other information provided by you;
• Aggregated information.

If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.

How We May Collect Other Information

We and our third-party service providers may collect Other Information in a variety of ways, including:

• Through your browser or device:  Certain information is collected by most browsers or automatically through your device, such as your Media Access Control address, computer type, screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, referring URL, and the name and version of the Services (such as the mobile application) you are using.  We use this information to ensure that the Services function properly.
• Through your use of an App:  When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
• IP Address:  Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the pages visited. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP address.
• From you:  Information such as your preferred means of communication is collected when you voluntarily provide it.

How we use Personal Information

We and our service providers may use Personal Information for legitimate business purposes including:

Providing the functionality of the Services and fulfilling your requests.

• To provide the Services’ functionality to you, such as arranging access to your registered account when applying for a position and providing you with related customer service.
• To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
• To complete your transactions and provide you with related customer service.
• To send administrative information to you, such as changes to our terms, conditions and policies.
• To allow you to send messages to another person if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

Providing you with our newsletter and/or other marketing materials and facilitating social sharing.

• To send you marketing related emails, with information about our Services, new products and other news about our company.
• To facilitate social sharing functionality that you choose to use.

We will engage in this activity because we have a legitimate interest or with your consent (where required).

Analysis of Personal Information for business reporting and providing personalized services.

• To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
• To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
• To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services either with your consent or because we have a legitimate interest.

Aggregating and/or anonymizing Personal Information.

We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information.  We do so to generate other data for our use, which we may use and disclose for any purpose.

Accomplishing our business purposes.

• For data analysis, for example, to improve the efficiency of our Services;
• For audits, to verify that our internal processes and service function as intended and are compliant with legal, regulatory or contractual requirements;
• For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
• For developing new products and services;
• For enhancing, improving, or modifying our current products and services;
• For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
• For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
• For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests;

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

For information on how we use Cookies and other technology, please read our Cookies and Similar Technology policy below.

How We May Disclose Personal Information

Your Personal Information may be disclosed:

• To partners and affiliates the purposes described in this Privacy Policy.
• To our third-party service providers, to facilitate services they provide to us, including website hosting, data analysis, information technology, payment processing, order fulfillment, customer service, email delivery, auditing, and other services;
• To identify you to anyone to whom you send messages through the Sites.

Other Uses and Disclosures of Personal Information

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

• To comply with applicable law and regulations, which may include laws outside your country of residence;
• To respond to requests from public and government authorities, which may include such authorities outside your country of residence;
• To cooperate with law enforcement to enforce our terms and conditions; and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
• In connection with a sale or business transaction.  We have a legitimate business interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business assets or stock (including in connection with any bankruptcy or similar proceedings.)

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we combine Other Information with Personal Information, we will treat the combined information as Personal Information as long as it is combined. We do not currently respond to browser do-not-track signals.

Third Party Sites

This Privacy Policy does not address, and we are not responsible for, the privacy or other practices of any third parties, including any third party operating any site or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.  In addition, we are not responsible for the information practices of other organizations, social media sites, web browsers or software.

Security

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

Choices and Access

Your choices regarding our use of your Personal Information

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by following the instructions contained in each email. We will try to comply with your request as soon as reasonably practicable. Please note that, if you opt out, we may still send you important administrative messages, from which you cannot opt out.

How you can access, change or suppress your Personal Information

If you would like to request to review, correct, update, suppress, restrict or delete Personal Information, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company, you may contact us at support@bossanovadata.com  We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

Retention Period

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Third Party Advertising

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.

You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/and http://optout.networkadvertising.org/#/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.

Use of the Service by Minors

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from such children.

Sensitive Information

Unless we request it, we ask that you not send us, and do not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, trade union membership or criminal background) directly to us.

Jurisdiction and Cross-Border Transfer

The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission and binding corporate rules to protect your Personal Information. You may obtain a copy of these measures by contacting support@bossanovadata.com or by following this link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

Third Party Payment Processing

We may use a third-party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information may be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.

Updates to this Privacy Policy

We may change this Privacy Policy. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contacting Us

Bossa Nova Data Solutions LLC, located at 5434 Heyward Square Place, Marietta, GA, 30068 is the company responsible for the collection, use and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at support@bossanovadata.com. Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

Additional Information regarding the EEA

You may also:

• Lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

California Privacy Notice

Pursuant to the California Consumer Privacy Act (CCPA), we are providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding 12 months. We have collected the following categories of Personal Information:

• Identifiers such as name and contact information; and
• Personal information such as credit or debit card information.

As described above, we collect this Personal Information from you and from other categories of sources: publicly available databases, sales channel partners, demand generation companies and joint marketing partners, when they share the information with us.  Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

We may disclose the following Personal Information to third parties for our operational business purposes:

• Identifiers such as name and contact information; and
• Personal information such as credit or debit card information.

We share Personal Information with our affiliates, service providers, and our business partners.

We have not “sold” Personal Information for purposes of the CCPA.

For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

If you are a California resident, you may request that we:

• Disclose to you the following information covering the 12 months preceding your request:
• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The specific pieces of Personal Information we collected about you; and
• The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
• Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please contact us in accordance with the “Choices and Access” section above.  We will respond to your request consistent with applicable law.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Cookies & Similar Technologies Policy

Last Revised: August 8, 2020

This Cookies & Similar Technologies Policy (“CST Policy”) describes the different types of cookies and similar technologies that are used on sites presented by Bossa Nova Data Solutions LLC (“Site”). We may change this CST Policy at any time. Please take a look at the “LAST REVISED” legend at the top of this page to see when this CST Policy was last revised. Any changes in this CST Policy will become effective when we make the revised CST Policy available on or through the Site.

If you have any questions, please contact us by email at support@bossanovadata.com, or write to us at the following address: Bossa Nova Data Solutions LLC, 5434 Heyward Square Place, Marietta, GA 30068.

What are Cookies and Similar Technologies?

Cookies are small text files that are stored on your computer when you visit our Site. Cookies keep us informed of which areas of the Site are most useful and which areas need improvement. They are used to facilitate navigation, optimize technical architecture, and enhance the Site with new features and capabilities. Cookies can also be used to deliver more relevant advertising to our visitors. Also used for this purpose, we also use technologies similar to cookies, such as pixel tags.

You can choose whether to accept the use of cookies and similar technologies in general by changing the settings on your browser, or by changing specific settings for the Site (as set out in Section 3 of this CST Policy). However, if you disable cookies and similar technologies, your experience on the Site may be diminished and some features may not work as intended.

What Cookies and Similar Technologies Do We Use?

Below we list the different types of cookies and similar technologies that are used on the Site. To the extent any personal information is collected through cookies, our Privacy Policy applies and complements this CST Policy.

Google Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Adobe Experience Cloud. Adobe’s Experience Cloud uses cookies and similar technologies to enable us to collect information to improve your online experience. Most browsers automatically accept cookies, but you can usually configure your browser to block all cookies, or to block only those set by companies other than the one whose website you are visiting. If you configure your browser to block cookies, you may prevent us from collecting information using Adobe Experience Cloud solutions on our website. Please see Your Privacy Choices to learn more about your choices for opting out of our use of Adobe Experience Cloud solutions.

Pixel tags. Pixel tags (also known as web beacons and clear GIFs) are used to, among other things, track the actions of users of the Site, measure the success of our marketing campaigns, and compile statistics about usage of the Site and response rates. 

Browser or Device Information. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Site you are using. Analytics systems like Google record this data to ensure that the Site functions properly on all devices.

Physical Location. Site analytics will collect the physical location of your device by, for example, using satellite, cell phone tower, or WiFi signals. This can be used to provide you with location-based services and content. We also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns.  Most modern browsers can either allow or deny the detection of your device’s location, and you can read more on how here. 

Device Fingerprinting. We may also use other technologies that are similar to cookies in order to best offer you content that will interest you based on prior activity on the Site, to better prevent fraud, and for authentication purposes. For example, we may gather device attributes and combine information collected by most browsers or automatically through your device to create a unique ID that identifies your browser or device to us with reasonable certainty. In this context we may collect, use, and combine the following information:

• Number of visits
• Last visit
• First visit
• External IP address
• Internal IP address
• Screen resolution
• Geolocation (latitude/longitude based on IP address)
• Device performance benchmark
• Device bandwidth benchmark
• Device user-agent (browser type, version)
• Device capabilities (Modernizer string for browser capabilities)
• Device operating system
• Device plugins installed
• Browser language
• Flash enabled or disabled
• Device time on file
• Keywords used if coming from search engine
• Pages visited
• Length of visit
• Referral page
• Mouse cursor position
• Mouse clicks
• Page scroll position

How Do I Manage Cookies?

Unless you have set your browser to automatically refuse them, cookies will be created on your system the second you visit our site. You can refuse or accept cookies from the Site at any time by changing the settings on your browser. Information on how to enable or disable cookies can be found on your Internet browser provider’s website via the help menu. You can also learn more how to control and delete cookies here: https://www.aboutcookies.org. Please be aware that if cookies are disabled, not all features of the Site may operate as intended, and your experience may be hampered or diminished. 

If you want to clear all cookies left behind by the websites you have visited, here are three options of programs that will clean tracking cookies from your device:

• http://www.lavasoft.com/products/compare/b/ad_aware_personal_security.php
• http://www.spybot.info/en/download/index.html
• http://www.webroot.com/consumer/products/spysweeper/

You can opt-out of having your anonymized browsing history within our Site by analytics cookies. We use the following providers and you can learn more about their privacy policies and how to opt-out of their analytics cookies below:

Adobe: http://www.adobe.com/privacy/opt-out.html

Google Analytics: http://www.google.com/analytics/learn/privacy.html