PRIVACY POLICY

BSB Design, Inc. (referred to below as “BSB”, “we”, “us” or “our”) takes the privacy of your personal data very seriously. We maintain the following Privacy Policy to protect the personal information you provide online. This Privacy Policy also provides notice to individuals whose personal information we process for our customers in connection with the services we provide to our customers. In this Privacy Policy we describe how your personal information may be used, including the types of information collected, the purposes for which the information is collected, anyone to whom the information may be disclosed outside of Interior Architects and the rights available to the you relating to the information we obtain via our website, www.bsbdesign.com (the “Site”) and as part of the services we provide to customers or otherwise make available via the Site (the “Services”).

1. WHAT INFORMATION IS COLLECTED BY US

The following types of information and content are collected by us.

A. INFORMATION YOU PROVIDE DIRECTLY TO US

We collect information when you submit information to us using any of the forms made available on the Site, which may include your name, phone number, address, email, and details related to a matter if you are an existing client. We may use your email to periodically send information related to events and information related to us, however you will have the option to opt-out of these emails if you wish.

B. ANALYTICAL INFORMATION

We use analytical tools to help us to measure the traffic and usage trends on the Site. These analytical tools work by collecting information sent by your device or our Site that assist us in improving the Site. We collect and use this information in the aggregate along with other visitors to the Site.

C. COOKIES AND LOG FILES

When you access and use the Site, we may use cookies or similar technologies to collect information about how you use the Site in order to provide improve the Site. Some features of the Site may be impaired or disabled if cookies are disabled.

Additionally, your browser will automatically create log file information each time you request to visit a website or web application. Log file information can also be created when content from a webpage or web application is downloaded by your browser or device. When you use the Site, our servers automatically record certain log file information. This information can include the web request, the Internet Protocol address or IP address, browser type, referring or exist page and Uniform Resource Locator or URL, the number of clicks and how you interact with the Site, domain pages, landing pages, pages viewed, and other information related to the Site. We may also use this information from emails that we send to you in order to determine what emails are opened and what links are clicked within particular emails. The collection of this information allows us to collect more accurate information to use for us to improve.

D. DEVICE IDENTIFIERS

Device identifiers are files or similar data structures that are stored or associated with your mobile devices, such as your tablet or phone, which are used to uniquely identify that particular mobile device. A device identifier may be associated with hardware within the device, the operating system of the device, or may be sent to the device by the Site.

When you use your mobile device to access the Site we may monitor, access, collect, monitor, on your device, or remotely store on your device one or more device identifiers. We use device identifiers to collect information about how you use the Services, which allows us to. If device identifiers are disabled on your mobile device it may impair or disable some of the Site features.

E. METADATA

Metadata is commonly viewed as the technical data that is associated with information and content, for instance, it describes how, when, and by whom a piece of information or content was collected and how it is formatted. We may collect the metadata inherently included in your information or content, or actively added by you through geotagging, comments, hashtags, and the like. The collected metadata is used as part of the Site functionality and we may also use it to improve the features available through the Site.

F. JOB APPLICANT DATA

If you are a job applicant, personal information we may hold about you may include the same data listed above in Personal Data, along with your education and work history, work authorization, professional licenses and/or certifications with your registration number(s), professional references, and confirmation that you are above the age of 18. We may seek to collect this information from you or from an employment agency acting on your behalf.

G. Client, Vendor and Consultant Data

If you are a client, vendor or consultant, personal information that we hold about you may include the same data listed above in Personal Data, along with your social media accounts, business address, email address, phone number and fax number, function/job title, company, and types of services provided.

BSB may request that you provide additional information such as your company’s legal status, date of incorporation, place of incorporation, your company’s related entities, your company’s shareholding details, your relationship to any government official, your company’s tax identification numbers, country of origin, business and professional licenses, your company’s insurer, broker and insurance policies, and other information you consent to provide us for purposes of performing contracts or services.

2. HOW INFORMATION IS USED BY US

In addition to the specific uses of information we detail in this Privacy Policy, we may also use information and content we collect to:

• help us improve our Site and Services
• provide content and information to you that is personalized, including email offers for content pertinent to your usage of the Site;
• assess your suitability for employment;
• improve the Site by monitoring, testing, diagnosing, repairing, and updating the Site, which can include developing and testing new features; and
• monitor metrics on an individual and aggregate basis, e.g. site traffic and demographics.

Consent

We may process your Personal Data based on your consent such as when you ask us to send certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal. However, if you withdraw your consent, we may not be able to provide you with the requested services.

Our Legitimate Interests

We may process your Personal Data if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests. For example, when we process your Personal Data to carry out fraud prevention activities and activities to increase network and information security, to market directly to you, to expand our business activities and to improve our services and the content and functionality of our Sites.

To Perform a Contract

We may process your Personal Data to administer and fulfill contractual obligations to you. If you do not provide us with your Personal Data, we may not be able to enter into the contract with you.

To Enable Us to Comply with a Legal Obligation

We may process your Personal Data to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts and to comply with legal process.

Necessary for the Exercise or Defense of Legal Claims

If you bring a claim against us or we bring a claim against you, we may process your Personal Data in relation to that claim.

3. HOW YOUR INFORMATION IS SHARED

We will neither rent nor sell your information to third parties outside of us without your consent. We will only share your information with outside sources as set forth within this Privacy Policy.

In instances where we may wish to disclose, or be required to disclose, your personal data to third parties, the disclosure of your data will take place only in accordance with the applicable law. These scenarios include disclosure to:

1. BSBs’ subsidiaries and affiliates.
2. Vendors or consultants to facilitate the provision of our services.
3. Third-party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons (including cloud service providers).
4. Another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization, change of legal form, dissolution or similar event.
5. Attorneys in connection with negotiation of a contract, dispute resolution, and other legal advice.
6. Tax advisors for purposes of tax filings, obtaining tax credits, negotiating tax liabilities, and other tax advice.
7. Public authorities where we are required by law to do so.
8. Any other third party where you have provided your consent.

Further, we may disclose your information to any person as required by law and specifically to any government agency if we believe in good faith that we must do so to comply with the law or that doing so is required to prevent, detect, investigate or remedy improper conduct potentially affecting BSB.

A. PARTIES WE MAY SHARE YOUR INFORMATION WITH

We may share your information, cookie information, log files, device identifiers, and location data, and usage data, with third-party organizations, or Service Providers that help us provide the Site to you. Our Service Providers will be provided access to your information only as is reasonably necessary to provide the Site and its related services and communications, under reasonable confidentiality terms. This may include combining your information with others in an aggregate, anonymized fashion.

B. PARTIES YOU MAY SHARE YOUR INFORMATION WITH

Information or Content you voluntarily disclose by using, posting, or displaying through the Site becomes available to the public as controlled by any applicable privacy settings that you set for the particular service you are using, e.g. Facebook or LinkedIn.

C. WHAT OCCURS IF BSB CHANGES CONTROL

If we sell or transfer part or all BSB or our assets to another organization, for instance in the course of a merger, dissolution, or acquisition, or the like, your information and content, and any other information collected through the Site may be among the items sold or transferred. The buyer or transferee will have to honor our commitments to you that we have made in this Privacy Policy.

D. RESPONSES TO PREVENT HARM AND LEGAL REQUESTS

In the event that we receive a legal request, such as a warrant, court order, or subpoena, we may access, preserve, or share your information or content in response if we have a good faith belief that the law requires us to do so. This may mean that we respond to requests made from outside the United States, if we have a good faith belief the response is required by the law in that jurisdiction, affects individuals in that jurisdiction, and is consistent with international standards.

4. HOW YOUR INFORMATION IS STORED

We store and process your information and content in the United States and any other country that we or our Service Providers keep facilities. In doing so, we may transfer information that we collect about you, including personal information across borders and around the world. Note that we may transfer information to a country that does not have the same data protection laws as your jurisdiction. Your registration, access, and continued use of the Site is your consent to the transfer of information to any of the locations we or our Service Providers keep facilities. The Site uses commercially reasonable safeguards to protect the information we collect through the Site. We are not responsible for the functionality, privacy, or security measures of any service, such as Facebook, LinkedIn, or the like, used in conjunction with the Services.

5. MAINTAINING YOUR INFORMATION

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. BSB has no responsibility or liability for the security of information transmitted via the Internet.

6. INFORMATION ON CHILDREN UNDER 13

We do not knowingly collect or solicit information from anyone under the age of 13 or allow them to register or use the Site. Our Terms of Use prohibit such individuals from using the Site. The Site and its content are not directed at or intended for children under the age of 13. In the event that we learn that we have collected personal information from a child under the age of 13 without parental consent, we will delete that information as soon as possible. If you believe that we might have any information from or about a child under 13, please contact us as indicated in Section 12 of this Privacy Policy.

7. THIRD-PARTY SERVICES

We are not responsible for any third-party service, web site, platform, application, or their respective users linked to or used in conjunction with the Site. Please remember that when you use a third-party service, such as LinkedIn, Facebook, or the like, our Privacy Policy and Terms of Use do not apply. Your use and interaction of those third-party services are subject to their policies and rules. In addition, you agree that we are not responsible and do not have control over any third-parties or the content. You also agree that by using a third-party service you are doing so at your own risk.

The Site may contain links to unaffiliated third-party websites. A link does not constitute an endorsement of the content, viewpoint, accuracy, opinions, policies, products, services, or accessibility of that website, and we are not responsible for their privacy practices. Once you link to another website from the Site you are subject to the terms and conditions of that website, including its privacy policy, and we therefore suggest that you read the privacy policies on all third party websites. We do not accept responsibility for the protection of any data supplied to other websites.

8. MISCELLANEOUS

We may modify this Privacy Policy periodically as we deem necessary, so please review it from time to time. Your continued use of the Site constitutes your acceptance of any such modification that we may make.

9. RETENTION AND DELETION

We will not retain personal information longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For personal information we receive from our customers, our customers have control of the purpose for collecting data, and the duration for which the data may be kept.

10. YOUR RIGHTS—UNITED STATES ONLY (INCLUDING CALIFORNIA)

Notice to Nevada, Virginia, Colorado, and Connecticut Residents

Nevada and Virginia residents and, beginning on July 1, 2023, Colorado and Connecticut residents and, beginning on December 31, 2023, Utah residents may also have the right to opt-out of the use of their personal information for targeted advertising (including online behavior advertising) and/or opt-out of the sale of their personal information by emailing info@bsbdesign.com

Notice to California Residents

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA/CPRA”) requires certain disclosures about how we collect, disclose, and sell the personal information of California consumers and the rights that California consumers may have under where we act as a business under CCPA/CPRA. When we use the term “personal information” in this California Statement, we are using that term as CCPA/CPRA defines it, which generally means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal information does not include publicly available, deidentified, or aggregate consumer information (which are all defined in CCPA/CPRA).  This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you and you should not rely on it.

The CCPA contains an exception that is relevant to us. Some of the CCPA’s privacy rights explained below do not apply to personal information collected in a business-to-business context. That is information reflecting a written or verbal communication or a transaction between us and a consumer, where the consumer is acting as an employee, owner, director, officer, or contractor of another entity and when the communication or transaction occur solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from such entity.

Right to Know About Personal Information Collected, Disclosed, or Sold

In general, the categories of personal information we collect, sources of that information, business and commercial purposes for why we collect and use it, and who we share it with, as well as our personal information retention practices, are as outlined in our Privacy Policy.

California law, however, requires we restate some of this information for specific categories that are defined in CCPA/CPRA. The type of personal information we collect and how we handle that personal information, including if we share or sell that personal information, depends on how you are specifically interacting with us and which Services you are inquiring about. In general, we have collected, disclosed for a business purpose, and sold the following categories of personal information and sensitive personal information from California consumers within the last twelve (12) months:

Collection of Personal Information

The following table identifies the categories of Personal Information that we collected for a business purpose in the 12 months preceding the Updated Date of this Privacy Policy.

Category	Examples	Collected
Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	No
Geolocation data.	Physical location or movements.	No
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
Professional or employment-related information.	Current or past job history or performance evaluations.	No
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No
Sensitive personal information	Social security, driver’s license, state identification card, or passport number; user name, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; contents of consumer’s mail, email, and text messages unless Thomson Reuters is the intended recipient of the communication; processing of biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.	No

Disclosure of Personal Information for a Business Purpose

BSB uses Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie with a randomly generated ClientID in your browser. This ID is anonymized and contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use Google Analytics to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. If you would like to access what browsing information we have – or ask us to delete any Google Analytics data – please delete your cookies, reach out to our Privacy Officer at the email at the end of this Policy, and/or install the Google Analytics Opt-Out Browser Add-On.

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Updated Date of this Privacy Policy

Category	Disclosed
Identifiers.	No
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	No
Protected classification characteristics under California or federal law.	No
Commercial information.	No
Biometric information.	No
Internet or other similar network activity.	No
Geolocation data.	No
Sensory data.	No
Professional or employment-related information.	No
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	No
Inferences drawn from other personal information.	No
Sensitive personal information	No

We did not sell Personal Information to third parties in the 12 months preceding the Last Updated date of this Privacy Policy. We do not knowingly collect or sell the Personal Information of minors under 13 years of age.

Your Privacy Rights

If you are a California consumer, you may have one or more of the following rights under CCPA/CPRA:

• Right to confirm we process your personal information and, if so, to request we disclose to you: (1) the categories of personal information we collected about you; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting, selling, or sharing personal information; (4) the categories of third parties to whom we disclose personal information; and (5) the specific pieces of personal information we have collected about you.
• Right to access (which may include a portable copy), correct, complete, or delete specific pieces of personal information we hold about you.
• Right to limit our use and disclosure of your sensitive personal information.
• Right to opt-out of the sale of personal information, as sale is defined under CCPA/CPRA.
• Right to opt-out of the sharing of personal information, as sharing is defined under CCPA/CPRA.
• Right not to receive discriminatory treatment for exercising your rights under CCPA/CPRA
• Additionally, California Civil Code Section 1798.83 may permit you the right to request information regarding the personal information about you we disclose to third parties for the third parties’ direct marketing purposes.

To make a request, you can contact us by emailing us at info@bsbdesign.com. 

Please provide us enough information to verify your identify. We will use information you provide to us to verify your request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as, for example, a copy of your driver’s license and/or a recent utility or credit card bill. You can designate an agent to make a request on your behalf by either: (1) having your agent send us a letter, signed by you, certifying that the agent is acting on your behalf and showing proof that they are registered with the California Secretary of State; or (2) by you and the agent executing and sending us a notarized power of attorney stating that the agent is authorized to act on your behalf. Please note that we may still require you to verify your identity before we process a request submitted by your agent. 

IMPORTANT: These rights are not absolutely guaranteed and there are several exceptions where we may not have an obligation to fulfill your request. We are only required to honor these rights to the extent that we act as a business/controller under CCPA/CPRA and the requested rights have been granted and apply to you under CCPA/CPRA. Please consult CCPA/CPRA to determine what rights may be available to you and when access to these rights is limited. You may appeal an adverse decision on your requests by emailing or writing to us; and you have the right to lodge a complaint to the California Attorney General if you are not satisfied with our responses to your requests or how we manage your personal information. However, we encourage you to first contact us so we can address your concerns directly.

11. ACCESSIBILITY

We strive to ensure that our services are accessible to people with disabilities. We will continue our efforts to constantly improve the accessibility of our site and services for all users. Despite our efforts, some content may not have yet been fully adapted to the strictest accessibility standards.

 If you are experiencing difficulty with any content on our site or require assistance with any part of our site, please contact us at info@bsbdesign.com com and we will be happy to assist.

12. HOW TO CONTACT US

Should you have any questions or concerns about this Privacy Policy or need to update certain personal information, please contact us:

• Email: info@bsbdesign.com

Last Policy Update:  July 11, 2023