Last updated: December 9, 2021

BTI recognizes that your privacy is very important, and we take it seriously. This Privacy Policy (“Privacy Policy”) describes our policies and procedures on the collection, use, disclosure, and sharing of your personal information when you use the BTI Platform.

This Privacy Policy applies to activities by BTI, Inc. and its affiliates and subsidiaries (collectively “BTI,” “we” or “us”). Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Service.

The Information We Collect

We collect information directly from individuals, from third parties, and automatically through the BTI Platform.

Account and Profile Information: When you create an account and profile on the BTI Platform, we collect your name, contact information (including your telephone number), demographic information, and other information you provide, such as topics that you know about or find interesting. Your name, photo, and any other information that you choose to add to your public-facing profile will be available for viewing by the public and other users of the BTI Platform. Once you create a profile, others will be able to see in your profile certain information about your activity on the BTI Platform, such as the questions and answers you post, your followers and who you follow, topics of interest to you, the information you list as credentials, and your edits to your content. For more information about your choices for publicly displayed information, see the section below about Your Choices.

Your Content: We collect the information and content that you post to the BTI Platform, including your questions, answers, photos, and comments. Unless you have posted certain content anonymously, your content, date and time stamps, and all associated comments are publicly viewable on the BTI Platform, along with your name. This also may be indexed by search engines and be republished elsewhere on the Internet in accordance with our Terms of Service. For more information about what you can change, see the below section on Your Choices.

Communications. Your contact information will be used to communicate with you (via email, phone, text message, through the BTI Platform or otherwise). When you communicate with us (via email, phone, text message, through the BTI Platform, or otherwise), we may maintain a record of your communication. By disclosing your contact information to BTI, you consent to our use of your contact information to communicate with you.

Integrated Service Provider and Linked Networks. You can connect your existing BTI account with certain third-party networks like Twitter or Google, for example (each a “Linked Network”). You can also elect to sign in or sign up to the BTI Platform through a Linked Network. If you elect to sign up through or connect a Linked Network, we receive certain profile and account information about you from the Linked Network. These Linked Networks may also appear in your profile, so that people can find you on these Linked Networks. The specific information provided to us by Linked Networks is determined by you and such Linked Networks, and may vary by network. In all cases, the permissions page for the Linked Network will describe the information being shared. You should consult their respective privacy policies for information about their practices. You may elect to use information from the Linked Network to populate your profile on the BTI Platform or to import your contacts to help you find and connect with them on the BTI Platform or to invite them to join. For information on your choices, including how to disconnect a Linked Network from your BTI profile, see the Your Choices section below. You may also elect to connect and make and receive payments to and from use through third-party networks (“Integrated Service Provider”); if you do so, you will be allowing us to pass to and receive from the Integrated Service Provider your login information and other user data for payment purposes.

Automatically Collected Information About Your Activity. We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information about your activities, such as your searches, page views, date and time of your visit, and other information about your use of the BTI Platform. We also collect information that your computer or mobile device provides to us in connection with your use of the BTI Platform such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, location, and requested and referring URLs. We also receive information when you view content on or otherwise interact with the BTI Platform, even if you have not created an account.

Engagement. We collect browsing information – such as IP address and location, date and time stamp, user agent, BTI cookie ID (if applicable), URL, unique advertising or content identifiers (if applicable) and time zone, and other information about user activities .

How We Use Your Information

We do not sell your personal information – such as your name and contact information – to third parties to use for their own marketing purposes. BTI uses the information we collect for the following purposes:

• Provide our Services. To provide you the services we offer on the BTI Platform and make the BTI Platform available to the public, communicate with you about your use of the BTI Platform, respond to your inquiries, provide troubleshooting, and for other customer service purposes.
• Personalization. To tailor the content and information that we may send or display to you in the BTI Platform, to suggest followers and content, to help others find your profile, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the BTI Platform.
• Advertising. To display interest-based advertising to you in the BTI Platform, to improve our advertising and measurement systems so we can show you relevant ads, to pre-fill forms in ads, and to measure the effectiveness and reach of ads and services. For more information, see the Ad Services section below about BTI Ads and Personalization.
• Marketing and Promotions. For marketing and promotional purposes, such as to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about third-party products and services.
• Analytics. To gather metrics to better understand how users access and use the BTI Platform; to evaluate and improve the BTI Platform, including the Ad Services and personalization, and to develop new products and services.
• Comply with Law. To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
• Prevent Misuse. Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy.

How We Share Your Information

We share information as set forth below, and where individuals have otherwise consented:

Service Providers. We may share your information with third-party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, customer service and support providers, as well as those who assist us in providing the Ad Services.

Affiliates. The information collected about you may be accessed by or shared with subsidiaries and affiliates of BTI, Inc., whose use and disclosure of your personal information is subject to this Privacy Policy.

Business Transfers. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event.

Legally Required. We may disclose your information if we are required to do so by law.

Protection of Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process , enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of BTI, its users, or others.

Your Content and Public Information. Your content, including your name, profile picture, profile information, and certain associated activity information is available to other users of the BTI Platform and may also be viewed publicly. Public viewing includes availability to non-registered visitors and can occur when users share your content across other sites or services. In addition, your content may be indexed by search engines. In some cases, we may charge for access to your content and public information on the BTI Platform. See the section below about Your Choices for information about how you may change how certain information is shared or viewed by others.

Metrics. We may share with our advertisers or publishers aggregate statistics, metrics and other reports about the performance of their ads or content in the BTI Platform such as the number of unique user views, demographics about the users who saw their ads or content, conversion rates, and date and time information. We do not share IP addresses or personal information, but certain features may allow you to share your personal information with advertisers on our platform if you choose to do so. We may also allow our advertisers or publishers to use Pixels on the BTI Platform in order to collect information about the performance of their ads or content.

Anonymized and Aggregated Data. We may share aggregated or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

As Directed by You. We may also share data as otherwise directed by you (for example, to fulfill a transaction).

Cookies, Pixels and Tracking

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your usage and browsing activities on the BTI Platform and across third-party sites or online services. We may combine this information with other information we collect about users. Below, we provide a brief summary of these activities.

Cookies. These are small files with a unique identifier that are transferred to your browser through our websites. They allow us to remember users who are logged in, to understand how users navigate through and use the BTI Platform, and to display personalized content and targeted ads (including on third-party sites and applications).

• Pixels, web beacons, clear GIFs. These are tiny graphics with a unique identifier, similar in function to cookies, which we use to track the online movements of users of the BTI Platform and the web pages of users of our Ad Services, and to personalize content. We also use these in our emails to let us know when they have been opened or forwarded, so we can gauge the effectiveness of our communications.
• Analytics Tools. We may use internal and third-party analytics tools, including Google Analytics. The third-party analytics companies we work with may combine the information collected with other information they have independently collected from other websites and/or other online products and services. Their collection and use of information is subject to their own privacy policies.

BTI Ads and Personalization

We may display personalized content (including from third-party content publishers) and personalized ads (including sponsored content), based on information that we have collected via the BTI Platform, and through our Pixels, widgets, and buttons embedded on third-party sites. We also may report aggregated or de-identified information about the number of users that saw a particular ad or content and related audience engagement information to users of our Ad Services and to publishers of content on the BTI Platform.

Advertisers who use our Ad Services may also provide us with information as part of their ad campaigns, including customer information (e.g., email addresses, phone numbers, or other contact information, demographic or interest data) in order to create custom audiences for personalizing their ad campaigns or for measuring the effectiveness of their ads; we only use this information to facilitate the particular advertiser’s campaign (including ad metrics and reporting to that advertiser); and we do not disclose this information to third parties (other than our service providers) unless required by law. We also do not disclose to the advertisers who use our Ad Services the names or contact information of their customers that were successfully reached as part of such campaigns without those customers’ consent.

Third-Party Ads on BTI

As described, we may also work with third parties such as network advertisers to serve ads on the BTI Platform and on third-party websites or other media (e.g., social networking platforms), such as Google AdSense and Facebook Audience Network. These third parties may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you.

How We Protect Your Information

The security of your information is important to us. BTI has implemented safeguards to protect the information we collect. However, no website or Internet transmission is completely secure. We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account, and closing your web browser when finished using the BTI Platform on a shared or unsecured device.

Access and Amend Your Information

You may update or correct your account information at any time by logging in to your account. You may also make a number of other adjustments to settings or the display of information about you as described in more detail in the following section about Your Choices.

Your Choices

You may, of course, decline to submit information through the BTI Platform, in which case we may not be able to provide certain services to you. You may also control the types of notifications and communications we send, limit the information shared within the BTI Platform about you, and otherwise amend certain privacy settings. Here is some further information about some of your choices:

Your Content. You may edit or delete the answers that you post at any time. Any questions you have posted may remain on the BTI Platform and be edited by other users. Any deleted content will be removed from third-party sites from which it has been shared via BTI’s standard sharing features; however we have no control over deletions or changes to your content if it has been shared manually by others. When you make edits to your content, other users will be able to see the history of those edits in your profile activity and on content edit logs.

Emails and Notifications. When you join the BTI Platform by signing up for an account or creating a profile, as part of the service, you will receive email digests containing content from the BTI Platform that we believe may match your interests. As permitted by law, you are also opting to receive notices, including by emails and text messages, about other content from the BTI Platform that may be of interest to you, such as Spaces that you follow or that match your interests. In addition, users may be able to send communications and invites to their imported contacts through their BTI account, by email, text, or phone. You can manage all your email, text messages, and notice preferences in your account profile settings, under your Emails and Notifications settings, but note that you cannot opt out of receiving certain administrative or legal notices from us. If you opt out of receiving emails or other notifications about recommendations or other information we think may interest you, we may still send you transactional emails and text messages about your account or any services you have requested or received from us.

Third parties may comment on your postings within the BTI Platform. In your profile, under your Privacy Settings, you can adjust whether to allow people to comment on your answers and posts. You can also adjust permissions about who you allow to send you messages on the BTI Platform.

h6>Followers. You can block the ability of another BTI user to follow you by selecting the setting for this in the other user’s profile. You can change whether or not you follow other users. h6>Profile discoverability. You can adjust your settings to block others from discovering your account by searching for your name or using your contact information, including when another user imports their contacts from a third-party service.

Topics and Spaces. You can change topics and Spaces that you are affiliated within your profile.

Credentials. You can change your credentials that are displayed in your profile or in connection with a specific answer.

Deleted or Deactivated Account. If you choose “Delete Account” in your profile’s “Privacy Settings,” then all of your content will be removed from public visibility on the BTI Platform, and it may not be restored by us, even if you change your mind. If you choose “Deactivate Account,” then you will no longer receive any communications from us, and users will not be able to interact with you; however your content will remain on the BTI Platform. Once you deactivate your account, you can reactivate it any time by choosing to log in.

Country-Specific Terms for India

India law defines ‘sensitive personal information’ to mean information relating to: (i) passwords; (ii) financial information such as bank account/credit card/debit card details; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) biometric information; (vii) any details relating to the above clauses as required for providing you with access to the BTI Platform; and (viii) any of the information received under above clauses for processing, stored or processed under lawful contract or otherwise. Unless otherwise specified in the Privacy Policy, ‘personal information’ will include ‘sensitive personal information’ as well. By using the BTI Platform and BTI’s services, you will be deemed to have consented to BTI’s collection, disclosure and transfer of your personal information. By way of illustration, you will have provided us such consent by your conduct if you choose to share your personal information while using the BTI Platform, such as by including sensitive personal information in Your Content or by providing sensitive personal information in your registration information.

If an individual in India deletes or deactivates their account, then their personal information will be deleted as per requirements under applicable law.

While transferring personal information collected from individuals in India, we will ensure that it is transferred to entities that offer at least the same levels of data protection as adhered to by us.