Below you will find CarrierBid’s Privacy Policy. These policies apply to CarrierBid and its affiliated companies (collectively “CarrierBid”). PLEASE READ THESE POLICIES CAREFULLY.

Effective Date: November 23, 2020.

This policy applies to CarrierBid and its affiliated companies (collectively “CarrierBid”).

CarrierBid understands that your privacy is important to you and is committed to safeguarding the confidentiality and privacy of personal information entrusted to it.

This Privacy Policy describes how CarrierBid handles and protects your personal information in connection with the hosting of this website, and the provision of its diverse business advisory services in the fields of corporate telecom and data networking consulting, strategic communications and technology (“Services”).

This policy applies to personal information which is collected and/or used by CarrierBid in its capacity as a controller as that term is defined in the EU General Data Protection Regulation (GDPR) and other similar laws (e.g., Brazil’s Lei Geral de Proteção de Dados). California residents should also review the section of this policy addressing their rights. The contexts in which this might occur are explored under “When do we collect personal information below.

When we provide Services to clients, we sometimes handle personal information as a processor. This means that we process the information solely on the instructions of our clients, who retain control of the information.

Therefore, if our use of your personal information is not covered by this policy, you may need to contact the client (and controller) on whose behalf the processing of your information is carried out.

Summary

CarrierBid collects personal information from and on behalf of its clients (e.g. about their employees and customers) to provide business advisory services to those clients. It also processes client personal information to manage its relationship with those clients. Further, CarrierBid also collects some personal information from visitors to this website, recruitment applicants, and attendees at CarrierBid events.

CarrierBid uses personal information to deliver its Services to clients. For its own purposes, it also uses personal information to analyze and improve how it delivers those services, to contact representatives of its clients or prospective clients and to market to them, and to administer recruitment and events.

If CarrierBid uses your personal information, you may have certain important rights which you can exercise. The rights you will be able to exercise will depend on how and why CarrierBid uses your information.

The primary point of contact at CarrierBid for questions regarding your personal information is info@carrierbid.com.

Who is your controller?

The CarrierBid entity responsible for your personal information will be the entity that originally collected information from or about you. If you have a direct interaction with CarrierBid (for example, you attend an CarrierBid hosted event), the identity of your controller may be disclosed to you in connection with that interaction. If we process your personal information while providing our Services to clients, your controller will be the CarrierBid entity providing the Services (assuming those Services are provided as a controller, see above for an explanation). Please note that the contact details for all CarrierBid entities in respect of data protection or privacy issues are the same and are as set out below.

Your Acceptance

In respect of personal information collected over this and other CarrierBid websites, your continued use of these websites constitutes your understanding of, and agreement to, the practices described in this Privacy Policy and elsewhere on the websites as well as any subsequent updates.

When do we collect personal information?

We collect information about you if:

  • you use this (or any other CarrierBid) website;
  • you enquire about, or engage CarrierBid to provide, its Services (either in a personal capacity, or as a representative for your employer or client);
  • the use of your personal information is reasonably necessary to provide our Services (in these circumstances, your personal information may be disclosed to us by our client who may, for example, be your employer or service provider, or we may obtain your personal information from a range of public or subscription sources, directly from you, or from your associates or persons known to you);
  • you apply for a position with CarrierBid;
  • you attend an CarrierBid hosted or sponsored event or webinar;
  • you contact us with any other enquiry, complaint, or notice.

What types of personal information are collected and what do we use it for?

The following is a summary of the types of personal information we collect, and the purposes for which that information is used.

Website Users

CarrierBid collects your name, address, e-mail address, telephone number and any other personally-identifiable information which you voluntarily provide when you submit an inquiry through the “Contact Us” tool. CarrierBid also collects other background information about you in connection with career-related inquiries that you submit through its website.

CarrierBid may also automatically collect personal information (through the use of Cookies or similar technologies, including your IP address, device identifier, browsing patterns on its websites, click stream data, and HTP protocol elements) to ensure the effective operation of the website or in order to align the presentation of our Services more closely to your requirements (for example, processing information about your broad geographic location to serve you with a local version of this website). This tracking information is stored in an anonymous, aggregated, and non-personal format, and is also used to understand and analyze trends, to administer the websites, and to learn about user behavior on the websites.

Please refer to our Cookie Policy for a more detailed overview on how CarrierBid uses Cookies.

In certain instances, CarrierBid may use IP addresses to help identify you when CarrierBid feels, in its sole discretion, that it is necessary to enforce compliance with this Privacy Policy, to protect its services, websites, systems, information, employees, business partners, subsidiaries, affiliates, users, customers or others, or when required by law or for law enforcement purposes.

CarrierBid’s Former, Current and Prospective Clients

If you submit an enquiry to CarrierBid about our Services (either over the website, or by emailing, telephoning or meeting with one of our colleagues), then we will process information such as your name, job title and contact information in order to respond to your inquiry.

If you attend an CarrierBid event or webinar, or if you associate with an CarrierBid colleague at, for example, an industry event, then CarrierBid may collect basic personal information, such as contact details, which you voluntarily provide (for example, by filling in a form or handing over a business card) in order to facilitate your participation in the event, and for the management of our relationship with you as an actual or prospective client.

If you or the organization you are associated with becomes an CarrierBid client, then we may process your personal information in order to:

  • learn about your business and to conduct screening prior to starting a new engagement (as well as basic contact information, this may mean processing compliance related information such as proof of your identity, information about your professional background, history of directorships and, in some circumstance, details of any criminal convictions or adverse media coverage);
  • carry out background checks for the purposes of complying with anti-money laundering and terrorist financing laws;
  • carry out client communication, service, billing and administration;
  • deal with client complaints; and
  • administer claims.

Taking account of applicable marketing laws, we also process personal information about our clients (former, current, and prospective) in order to:

  • send our clients newsletters, know-how, promotional material, and other marketing communications;
  • invite our clients to events (and arrange and administer those events).

Performing Services for Our Clients

As discussed above, many of our Services involve the processing of personal information. In the majority of cases, personal information is provided to us in strict confidence, subject to restrictive undertakings on its use / disclosure.

Illustrative examples of the use of personal information in connection with our Services, and the legal bases we rely upon for using personal information, are set out in Annex 1 (Use of Personal Information for our Services).

Other Uses

If you apply for a position with CarrierBid, we will need to collect personal information in order to consider your application, and during any interview and assessment phase.

Finally, if you contact us for any other reason, we will collect basic contact details, as well as any other personal information relevant to the reason for your inquiry, in order to resolve that inquiry.

What is our legal basis for collecting personal information?

All processing (i.e. use) of your personal information is justified by a “lawful basis” for processing. In the majority of cases, processing will be justified on the basis that:

  • the processing is necessary for the performance of a contract or letter of authorization (LOA) to which you are a party, or to take steps (at your request) to enter into a contract (e.g. where you request certain Services as an individual client, or where we help advise your employer or service provider on fulfilling an obligation to you under a contract);
  • the processing is necessary for us to comply with a relevant legal obligation (e.g. where we are required to collect certain information about our clients for tax or accounting purposes, or where we are required to make disclosures to courts or regulators); or
  • the processing is necessary for the performance of a task carried out in the public interest (e.g. background checks for anti-money laundering and terrorist financing purposes); or
  • the processing is in our legitimate interests, subject to due consideration for your interests and fundamental rights (this is the basis we rely upon for the majority of the processing of personal information in connection with the provision of our Services, and also for the purposes of most client on-boarding, administration and relationship management activities).

In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required by applicable law to obtain your prior consent in order to send you marketing communications.

Before collecting and/or using any special categories of data (as that term is defined in the GDPR), or criminal record data, we will establish a lawful exemption which will allow us to use that information. This exemption will typically be:

  • your explicit consent;
  • the establishment, exercise, or defense by us or third parties of legal claims; or
  • other uses allowed by applicable law including context specific exemptions provided for under local laws of EU Member States and other countries implementing the GDPR, such as in relation to the processing of special category data for the purposes of preventing or detecting fraud in relation to instructions from potential clients.

Disclosure of Personal Information to Third Parties

CarrierBid will not disclose your personal information to third parties other than as described in this Privacy Policy unless CarrierBid has your permission or is required or permitted by law. CarrierBid may share such information with its affiliates as necessary to carry out the purposes for which the information was supplied or collected. Similarly, third party contractors, consultants and/or vendors engaged by CarrierBid to provide services may have access to your personal information. These third parties will be subject to their own data protection requirements providing the same or greater level of security provided by CarrierBid and in most instances will also have entered into a written agreement with CarrierBid which addresses the protection of your personal information.

CarrierBid may also disclose your personal information for the purposes of:

  • responding to requests from law enforcement agencies, regulators, or courts, or to subpoenas, search warrants, or other legal requests;
  • the prevention and/or detection of crime;
  • establishing legal rights or to investigate or pursue legal claims;
  • a merger, acquisition, or corporate restructuring to which CarrierBid is subject;
  • preventing risk of harm to an individual.

Information Security

CarrierBid has reasonable technical safeguards, security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Measures we take include placing confidentiality requirements on our staff members and service providers, limiting access to your personal information on a “need to know” basis, and providing training to appropriate CarrierBid personnel. We also maintain comprehensive policies addressing data incident response protocols. Our IT Security Program is audited on a regular basis.

Despite CarrierBid’s best efforts, however, security cannot be absolutely guaranteed against all threats.

Retention of your personal information

CarrierBid retains your personal information for the period of time required for the purposes for which it was collected, any compatible purposes which we subsequently establish, or any new purposes to which you subsequently consent, or to comply with legal, regulatory and CarrierBid policy requirements. This period of time will usually be the period of your, or the relevant client’s, relationship or contract with CarrierBid plus a period reflecting the length of time for which legal claims may be made following the termination of such relationship or contract. Some information (such as call recordings, tax records and certain information required to demonstrate regulatory compliance) may need to be kept for longer. Personal information will be kept for a shorter or longer period of time if so required by law or an CarrierBid policy, if the information becomes subject to a legal hold (for example, following a communication from our regulator) or if we have identified through a data protection impact assessment that a different retention period is appropriate.

Right to Access

You have the right to access personal information which CarrierBid holds about you, together with certain information about how and why your personal information is processed.

Right to Rectification

You have a right to request us to correct your personal information where it is inaccurate or out of date.

Right to be Forgotten (Right to Erasure)

You have the right under certain circumstances to have your personal information erased. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the information.

Right to Restrict Processing

You have the right to restrict the processing of your personal information, but only where:

  • its accuracy is contested, to allow us to verify its accuracy; or
  • the processing is unlawful, but you do not want it erased; or
  • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
  • you have exercised the right to object, and verification of overriding grounds is pending.

Right to Data Portability

You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party. Please note that CarrierBid rarely relies upon consent as a legal basis, and the performance of a contract basis will only be relevant to the extent that you, as an individual, are party to a contract with CarrierBid or a client, and our use of your personal information is necessary for the performance of that contract.

Right to Object to Processing

You have the right to object to the processing of your personal information at any time, but only where that processing is based on our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

If you reside in the European Economic Area (EEA) and would like to exercise your right to access, review, correct or discuss how your personal information is processed by CarrierBid please contact us at info@carrierbid.com.

If you reside outside of the EEA you can also make a request to update or remove information about you by contacting info@carrierbid.com.CarrierBid will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

In addition, under applicable local law you may have the legal right to lodge a complaint with the relevant supervisory authority or local data protection authority.

Important Additional Information for California Residents

This section provides information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”). The CCPA generally requires that businesses provide California consumers information about how we use their personal information, whether collected online or offline, and this document is intended to satisfy that requirement. However, the CCPA notice requirement does not apply where we are providing services to our clients, receive personal data and use it solely to provide service to a client and function as a “service provider” within the meaning of the CCPA.

In addition, this policy does not apply to information that we collect regarding employees or in the course of providing or receiving business-to-business services (job applicants should review the CCPA Applicant Privacy Notice on our Careers page).

Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

Categories of Personal Information that We Collect, Disclose, and Sell

Below please find the categories of personal information about California residents that we may collect and may disclose to third parties or service providers for a business purpose (more detailed information about the types of information we collect and use can be found in Annex I).

Categories of personal information Do we collect? Do we disclose for business purposes? Do we sell?
NAME, CONTACT INFORMATION AND IDENTIFIERS: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. YES NO NO
CUSTOMER RECORDS: Paper and electronic customer records containing personal information, such as 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. YES NO NO
PROTECTED CLASSIFICATIONS: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information. NO NO NO
PURCHASE HISTORY AND TENDENCIES: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES NO NO
BIOMETRIC INFORMATION: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. NO NO NO
USAGE DATA: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement. YES NO NO
GEOLOCATION DATA: Precise geographic location information about a particular individual or device. NO NO NO
AUDIO/VISUAL: Audio, electronic, visual, thermal, olfactory, or similar information. NO NO NO
EMPLOYMENT HISTORY: Professional or employment-related information. YES NO NO
EDUCATION INFORMATION: Information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99). NO NO NO
PROFILES AND INFERENCES: Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO NO NO

California Residents’ Rights

California law grants California residents’ certain rights and imposes restrictions on business practices as set forth below.

Right to Opt-out. California residents have the right to opt-out of our sale of their personal information. We do not and will not sell your personal information.

Minors. We do not sell personal information about residents who we know are younger than 16 years old.

Notice at Collection. We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.

Verifiable Requests to Delete, and Requests to Know. Subject to certain exceptions, California residents have the right to make the following requests, at no charge, up to twice every 12 months:

Right of Deletion: California residents have the right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary for any of a list of exempt purposes.

Right to Know – Right to a Copy: California residents have the right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.

Right to Know – Right to Information: California residents have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:

  • categories of personal information collected;
  • categories of sources of personal information;
  • business and/or commercial purposes for collecting and selling their personal information;
  • categories of third parties/with whom we have disclosed or shared their personal information;
  • categories of personal information that we have disclosed or shared with a third party for a business purpose; and
  • categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

Submitting Requests. Requests to exercise the right of deletion, right to a copy, and / or the right to information may be submitted to info@carrierbid.com or by contacting us at 480-345-3333 or 888-706-5656. We will respond to verifiable requests received from California consumers as required by law.

Right to Non-Discrimination, and Incentives. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information.

California Privacy Rights under California’s Shine-the-Light Law

Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. California residents who would like to make such a request may submit a request in writing using the contact information provided below. The request should attest to the fact that the requester is a California resident, and provide a current California address.

Marketing

CarrierBid may send you information related to its services, products, and events that we believe are of interest to you. This information may be sent by post or via email. If at any point you no longer prefer to receive marketing communications from CarrierBid you can (i) unsubscribe from CarrierBid communications sent by email using a link provided in marketing emails sent from CarrierBid; or (ii) contact us to exercise your right to prevent all forms of marketing (both post and email).

Children

CarrierBid’s websites are not intentionally designed for or directed at children under the age of 13. It is CarrierBid’s policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

Links

CarrierBid websites may contain links to other sites, including websites maintained by CarrierBid affiliates that are governed by other privacy policies that may differ somewhat from this one. Users should review the privacy policy of each website visited before disclosing any personal information. To the extent that CarrierBid provides links to third party websites, such links do not constitute an endorsement, sponsorship, or recommendation by CarrierBid of the third parties, the third party websites, or the information contained on those websites, and CarrierBid is not responsible or liable for your use of such third party websites. Where appropriate you should review the privacy polices of any websites or applications before submitting personal information.

Changes to this Policy

By using CarrierBid websites you consent to the collection, use and storage of personal information as described in this Privacy Policy and elsewhere on the websites. CarrierBid reserves the right to make changes to this Website Privacy Policy from time to time. CarrierBid will notify you by posting amendments to the Privacy Policy on this website.

Contact Us

If you have questions or concerns regarding this policy or CarrierBid’s personal data processing policies, please contact CarrierBid at: info@carrierbid.com.

If you reside in the EEA and have questions or concerns regarding this policy or processing of your personal information by CarrierBid please contact us at info@CarrierBid.com.

ANNEX 1: USE OF PERSONAL INFORMATION FOR OUR SERVICES

Service Why is personal information used? What legal bases are relied upon?
Strategic Communications CarrierBid has a team of experts who are experienced in designing and implementing communication strategies for clients. In order to provide clients with tailored, intelligence led strategies, CarrierBid may be given, and may pro-actively collect through its own research, personal information about key individuals or parties involved in an issue or incident about which our client has requested communications advice. Legitimate interest in providing public relations consultation to clients, including in relation to the handling of situations relating to or involving particular individuals. *

*In all cases where legitimate interests is relied upon as a lawful basis for processing Personal Data, CarrierBid takes steps to ensure that its legitimate interests are not outweighed by any prejudice to the rights and freedoms of the underlying data subjects. This is achieved in a number of ways, including through the application of principles of data minimization and security, and by taking steps to ensure that personal information is only collected or otherwise obtained where it is relevant to the provision of Services to a client, and where access to personal information for CarrierBid is reasonably necessary for the provision of those Services.

CarrierBid is the DBA for Berean Holdings LLC, an Arizona LLC

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