Privacy Policy of BHRS Group LLC
This privacy notice (“Privacy Notice”) is intended to provide you with specific details about how BHRS Group LLC (“BHRS Group LLC,” “we,” and “us”) collects and processes your personal and personally identifiable information through your use of its app and associated services (collectively, the “Avalon app”).
You understand and agree that BHRS Group LLC may store and process your personal information on computers located outside of your jurisdiction, including, but not limited to,in the United States. By using the Website, you agree to the collection and processing of your personal or personally identifiable information outside of your jurisdiction.
Before using the Website or providing information to us, please carefully review this Privacy Notice. By using or accessing the Website, you agree that we may collect and use your personal and personally identifiable information in accordance with this Privacy Notice, as revised from time to time. BHRS Group LLC may modify,amend, replace, or suspend this Privacy Notice at any time. If you have any
questions or suggestions regarding our Privacy Notice, or if your personal
information is not accurate or complete, please contact us at:
Privacy Officer
BHRS Group LLC
585 Prospect Street,
Suite 301B, Lakewood, NJ 08701
compliance@bhrsgroup.com
By providing BHRS Group LLC with your personal or personally identifiable data and using the Avalon app, you warrant that you are over the age of eighteen (18) or otherwise above the age of majority within your jurisdiction. If you are younger than eighteen (18) or the age of majority within your jurisdiction, please do not use Avalon app and please do not provide personal information to us.
What information do we collect and how do we use it?
When you use the website, we may collect personal or personally identifiable
information from you (“PII”). PII may include any information that identifies,
relates to, describes, references, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular
individual. It does not include anonymized data.
We may collect and process the following categories of PII about you:
·Communication Data. Communication data includes any communication that you may
send to us through the website, email, or social media. We process this data to
communicate with you by email or other means, to provide you with customer
support, to record logs of our communication, and to store information to
respond to legal claims. BHRS Group LLC’s lawful ground for collecting and
processing this PII is to respond to communications sent by you to us, to keep
records of our communication, and to pursue or defend against legal claims.
·User Data. User data includes data about how you use the website and any
data that you post to or authorize through the website, such as your name,
address, country, phone number, and email address. This includes data stored in
persistent cookies when you login to the website and analytics data that is
collected when you use the website. We collect and process this data to operate
the website, to authenticate you as a user of the website, to ensure that
timely and relevant content is provided to you, to secure the website, to
ensure that the website operates in a fast and efficient manner, and to
maintain backups of the website. BHRS Group LLC’s lawful ground for processing
this user data is its legitimate business interests in administering and
offering the website and to fulfill your orders for products through the
website.
·Technical Data. Technical data includes data about your use of the website,
such as your IP address, your login data, your phone number, your mobile device
model, your operating system, your geolocation, and your time zone. We may
collect this data from your use of the website and from advertising IDs. BHRS
Group LLC processes this data to analyze your use of the website, to route
website traffic, to administer and secure the website, to provide
location-relevant content, and to troubleshoot problems with the website. BHRS
Group LLC’s lawful ground for collecting and processing this technical data is
its legitimate interests in administering and offering the website and to grow
its business and marketing strategy.
·Marketing Data. Marketing data includes data about your preferences in
receiving and interacting with BHRS Group LLC’s advertisements or content on
the website or on third party websites. We collect this data from your use of
the website and from third party advertising IDs created through advertising
programs, such as Google Advertising IDs, Facebook Advertising IDs, and TikTok
Advertising IDs. BHRS Group LLC does not connect advertising identifiers to
persistent device identifiers, such as MAC addresses or mobile device IDs. BHRS
Group LLC’s lawful ground for collecting and processing this marketing data is
its legitimate interests in administering and offering the website and to grow
its business and marketing strategy by providing advertisements, including
remarketing advertisements, to you.
·Personally Sensitive Data. Personally sensitive data includes data
about your race or ethnicity, religious or philosophical beliefs, sex life,
sexual orientation, political opinions, union membership, or information about
your health. BHRS Group LLC does not collect personally
sensitive data.
BHRS Group LLC will only use your PII for the purpose for which it was collected. If BHRS Group LLC needs to use your PII for an unrelated new purpose, BHRS Group LLC will provide you with notice of this new use and will explain the lawful ground for such processing. BHRS Group LLC may process your PII without your knowledge or consent where required or permitted by law.
BHRS Group LLC does not use your PII to automatically make any decisions or to create an automated profile about you.
What information do we collect from third parties and how do we use it?
BHRS Group LLC may collect data about you through cookies and other technologies. This helps BHRS Group LLC understand how you use the website and to understand any patterns that may be associated with your use of the website. This aids BHRS Group LLC in developing or improving its website and marketing communications in response to your needs or wants.
BHRS Group LLC may use session or persistent cookies. Session cookies are only stored on your computer or mobile device during your use of the website and are automatically deleted when you close your web browser. Session cookies may be used to direct internet traffic to a server that is closer to you or to allow us to identify you as you move between pages of the website. Persistent cookies are stored as a file on your computer or mobile device that remains on your computer or mobile device even after you close your web browser. Persistent cookies can be read by the website that created the cookie when you revisit it again. BHRS Group LLC may use persistent cookies to authenticate you when you return to the website so that you do not have to login again or when it utilizes Google Analytics or
other analytics providers, which is intended to track the origin and behavior
of traffic to the website. BHRS Group LLC may use the following analytics
providers, and you are directed to review their cookie policies:
BHRS Group LLC may also receive data from third parties including analytics providers or advertising networks such as Google, Facebook, TikTok, or Apple. These third parties may be based outside of your jurisdiction.
How do we use your information for marketing communications?
As stated above, BHRS Group LLC’s lawful ground for sending you marketing
communications is either consent or its legitimate business interests, such as
to grow its business by advertising products to you. BHRS Group LLC may send you marketing communications if you have asked for information concerning its goods or services or if you have agreed to, and have not opted out from, receiving
marketing communications. You may ask BHRS Group LLC to stop sending you
marketing messages at any time by logging into the website to adjust your
marketing preferences within your user account or by following the opt-out link
in any marketing message sent to you. If you opt out of receiving marketing communications,your opt-out does not extend to PII provided for other purposes.
When do we disclose your information?
BHRS Group LLC may share your PII with the following parties:
·Service providers that provide BHRS Group LLC with information technology, software as a service, cloud storage, or other administrative services;
·Service providers, such as distributors, warehouses, or wholesalers, that provide BHRS Group LLC with products for sale to you in order to fulfill your product orders;
·COM’s accountants, auditors, insurers, or attorneys;
·Law enforcement agencies upon the receipt of a subpoena or court order or where necessary to protect BHRS Group LLC’s personnel or property.
·Government bodies that require BHRS Group LLC to report its processing activities.
BHRS Group LLC may also transfer PII to third parties when it sells, transfers, or merges any part of its business or assets.
BHRS Group LLC requires all third parties that receive a transfer of PII from BHRS Group LLC to maintain the same level of respect for the protection of PII as BHRS Group LLC and BHRS Group LLC only allows third parties to process your personal data for the specific purposes listed in this Privacy Notice.
How do we protect your information?
We implement a variety of security measures to maintain the safety of your
personal information, including when you place an order. However, no security
measures are impenetrable and there are always security risks. BHRS Group LLC
will notify you and any regulatory body of any breach of your PII or BHRS Group
LLC security measures if it is legally required to do so.BHRS Group LLC has put into place data security measures to protect your PII. BHRS Group LLC allows access to your PII only by employees and service providers who have a need to know or access your PII on BHRS Group LLC’s instructions. BHRS Group LLC will notify you and any regulatory body of any breach of your PII or BHRS Group LLC’s security measures if it is legally required to do so.
Do we use cookies?
Yes, as stated above, we do use persistent and session cookies. Cookies are
small files that a site or its service provider transfers to your computer’s
hard drive through your web browser (if you allow) that enables the sites or
service providers systems to recognize your browser and capture and remember certain information.
We use cookies to help us remember and process the items in your shopping cart,understand and save your preferences for future visits, and compile aggregate
data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
For how long do we retain your data?
We will only retain your PII for so long as necessary to fulfill the purposes for which it is collected under this Privacy Notice or for the purposes of satisfying any
legal, accounting, or reporting requirements. With respect to location data,
technical data, usage and interaction data, and marketing data, we may retain
this data for so long as it is relevant to the uses disclosed in this Privacy
Notice. We may retain account data, public data, and communications data for so
long as you maintain a user account with BHRS Group LLC, and we may retain this data for longer periods where there is a need to retain this data to comply
with BHRS Group LLC’s legal obligations, such as the preservation of electronic
evidence or compliance with a preservation order.
Right of Access,Rectification, Correction, Erasure, Transfer, and Withdrawal
Under the law, you may have a right to request access to your PII for rectification, correction,erasure, transfer, or restriction, or to object to its processing or withdraw your consent. If you wish to exercise any of these rights, please contact BHRS Group LLC’s Data Protection Officer as disclosed in this Privacy Notice.
You do not need to pay a fee to access your PII or to exercise your rights. However, BHRS Group LLC may charge a reasonable fee if your request is unreasonable or excessive.
To confirm your request, BHRS Group LLC may need to request specific information from you as a security measure to ensure that PII is not disclosed to an unauthorized third party. BHRS Group LLC will attempt to respond to all legitimate requests within thirty (30) days.
California Privacy Rights
The following rules apply solely to visitors, users, and others who are residents of the State of California. California residents have the right to be notified which categories of PII are being collected and the purposes for which the PII is being used. In particular, we collected the following categories of PII (A, B, D, E, and F) as
defined in the California Consumer Privacy Act within the last twelve months.
Our uses of this PII are detailed above in this Privacy Notice:
Category | Examples | Collected |
|---|
A. Identifiers | Real name, alias,
postal address, unique personal identifier, online identifier, Internet
Protocol address, email address, account name, or other similar identifiers. | YES |
B. Personal
information categories listed in the California Consumer Records statute
(Cal. Civ. Code § 1798.80(e)) | Name, signature,
address, telephone number, bank account number, credit card number, debit
card number, or any other financial information. | YES |
D. Commercial | Records of products
purchased. | YES |
F. Internet or other
similar network activity | Browsing history,
search history, information on a consumer’s interaction with a website,
application, or advertisement. | YES |
G. Geolocation data | Physical location or
movements. | YES |
We obtain these categories of PII directly from California residents when they complete forms through our website or provide it to us as a part of a transaction or inquiry concerning our products. We also obtain these categories of PII indirectly from California residents while observing their actions on our website and from third parties or service providers that they have authorized to receive and share PII.California residents
have a right to request that we disclose what PII we collect from you and
whether, and how, we disclose or sell that PII. California residents may also
request that we delete any personal information collected or maintained by us
from you.
California residents may also have the right to opt out of the sale of their personal information by contacting us or, where available, by clicking a link or icon associated with an advertisement. Specifically, this link or icon may state “Do Not Sell My Personal Information” or “Do Not Sell My Info.” By selecting this link or icon,
you “Opt Out,” which means that you have opted out of the sale of your personal
information as set forth in the California Consumer Privacy Act. However, even
though you may have opted out, you may still see interest-based advertisements.
To learn more about interest-based advertising across websites and additional
opt-out choices, you can visit http://optout.aboutads.info. If you opt-out of the sale of your personal information but do not opt out of interest-based advertising more generally,you may still receive ads tailored to your interests based on PII that was not sold by us, personal information that was sold to downstream participants at least 90 days before you opted out, or personal information that was sold by other sources from which you have not opted out. To submit a request for a list of the categories of personal information collected from you or to request that BHRS Group LLC delete your personal information, please email us at compliance@bhrsgroup.com or send a letter to us at the following address:
Privacy Officer
BHRS Group LLC
585 Prospect Street,
Suite 301B, Lakewood, NJ 08701
compliance@bhrsgroup.com
To verify your request, we may request certain information from you to confirm that you are a BHRS Group LLC user, such as your phone number, username, email address, city, state, or geographic location. You may also designate an authorized agent to make a request to BHRS Group LLC to disclose or delete your personal information. To do so, you must provide BHRS Group LLC with proof that the
individual or business has been appointed as your agent, such as by providing a
signed power of attorney form and provide accurate responses to any information requested by BHRS Group LLC that may be necessary to confirm that you are a BHRS Group LLC user, such as your phone number, username, email address, city, state, or geographic location. California residents have a right not to receive
discriminatory treatment by BHRS Group LLC for their exercise of these rights
conferred under California law.
Third Party Links
BHRS Group LLC’s website may include links to third-party websites and applications. By clicking on third party links, you may allow third parties to collect or share data about you. BHRS Group LLC does not control these third-party links and you are advised to review their respective privacy policies.
Responding to Do Not Track Signals
You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. Our website is not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what “do not track” means in this context, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set. Nevada Residents
If you are a resident of Nevada, you may provide notice to us to limit the sale of your PII to third parties for resale or licensing purposes. However, we do not sell your PII for such use. To notify us that you wish to limit the sale of your PII to third
parties for resale or licensing purposes, you may send us an email to compliance@bhrsgroup.com with the subject line, “Nevada Do Not Sell Request,” along with your name, address, and user account information.
Virginia Residents
BHRS Group LLC does not control or process the personal data of at least 100,000 Virginia residents or control or process the personal data of at least 25,000 Virginia residents and derive more than 50% of its gross revenue from the sale of personal data. For these reasons, the Virginia Consumer Data Protection Act (VCDPA) does not apply to BHRS Group LLC’s collection and use of PII.
Changes to our Privacy Notice
Whenever BHRS Group LLC changes its Privacy Notice, we will post those changes to this Privacy Notice on the app and other places that we deem appropriate.
Your use of the Avalon app following these changes indicates your consent to
the practices described in the revised Privacy Notice.
Contacting Us
If you have any questions about this Privacy Notice or the manner by which we collect or use Personal Information about you, email us at compliance@bhrsgroup.com.