Privacy Notice
Last Updated: September 2023
This Privacy Notice (“Privacy Notice” or “Notice”) explains the privacy practices of Alkhemist LLC. (“Alkhemist”, “we” or “our”). It describes the ways in which we collect, use (and don’t use), and disclose or sell the information we receive from you, including from our business customers who use our services to interact with you as well as information we receive via our websites (such as bullnocho.com), which we define and describe in this Notice. Our website is referred to collectively in this Notice as the “Sites.” Your ConsentBy using the Sites and Services (as defined below), you consent to the terms of this Privacy Notice. If you do not agree to the terms and conditions of this Privacy Notice, including having your “Personal Information” used in any of the ways described in this Privacy Notice, then do not provide us with your information. If you don’t provide us with your information you may not be able to use certain parts or features of the Sites or the Services.Use of the Sites and Services by you following our posting of a new Privacy Notice on our Sites constitutes your acceptance of the Privacy Notice as modified. In the event we materially change the way in which we use your Personal Information, where required by law we will provide you with notice and ask you to affirmatively accept these material changes. This Privacy Notice applies to all of Alkhemist’s Services. This Privacy Notice is incorporated as part of Alkhemist’s Terms of Use, which apply to your use of the Site and Services. How to Contact UsIf you have any questions about this Privacy Notice, please contact us by emailing privacy@bullnocho.com. You can also contact us by phone at +1 323-591-5505.Description of Our ServicesThe Alkhemist “Services” consist of online, offline and mobile offerings that help our customers track and optimize their call services, including software that can track and record customer calls and that give our customers the ability to use online communication for measuring marketing campaigns, improving customer service, and improving sales performance. Our services may change and be updated from time to time, and further details on our services can be found at www.bullnocho.com/services/.Collection of Personal InformationWhen you register on our Sites or use our Sites or Services, we collect your Personal Information. In this Privacy Notice, the term “Personal Information” refers to information that tells us specifically who you are, such as your name, phone number, email, and postal address, as well as other data associated with you that is deemed to be personal information under the privacy laws of different states or countries. Privacy laws may refer to such information as, for example, “personal data” (UK and EU), “personally identifiable information” (US FTC regulations and various state laws), or “personal information” (California privacy laws). We use Personal Information to refer to all of these terms.Alkhemist collects the information on the callers that call our business customers through the dedicated phone numbers that our business customers have purchased through Alkhemist (or numbers our business customers have requested be ported into Alkhemist from another provider). This information includes: (1) the caller’s phone number; (2) the name displayed on the Caller ID (when available); (3) call recordings and transcripts of calls you place to us or to our customers when using our Services; and (4) other data that may be correlated through our business customer’s data sources (for example, customer data from CRM systems), personal data sources (for example, social contacts and email inboxes), and third party data services (for example, White Pages, Contactive, FullContact). The data is collected in order to display relevant caller information related to an incoming phone call. With respect to our use of data collected from third party data services, the transmission of such data is encrypted using TLS encryption and all data cached is deleted and is not stored by Alkhemist for any longer than necessary for business purposes. We do not share this data outside of the Services. We may use this data to increase the accuracy of caller information and provide more specific information to our customers regarding the call location, to describe the types of businesses that engage with our customers and to determine call histories for analytics purposes. We also collect information on our customers’ website visitors via our JavaScript, as described in more detail in our Cookie Notice. This information includes IP address, User Agent, URLs visited on our customers’ websites, and other data that may be accessible through the JavaScript code installed on the customers’ websites. We use various in-house and third-party analytics tools to analyze the activity of our own customers as they use our Sites and Services. You may opt out of providing your Personal Information by not entering it when asked or by following the instructions provided elsewhere in this Privacy Notice and our Cookie Notice. How We Use Your Personal InformationPersonal information you provide to Alkhemist or our customers who use our Services to interact with you may be used to:
Disclosures and Transfers of Personal InformationWe do not share with or disclose Personal Information to third parties, except when one or more of the following conditions is true:
Opting Out of Alkhemist Marketing in the United StatesYou may opt out of being contacted by us, or receiving such information from us, at any time by sending an email to privacy@bullnocho.com. Current customers can either send an email to privacy@bullnocho.com or submit a ticket through https://support.bullnocho.com/. You may be able to stop receiving some marketing communications, such as emails, by updating your preferences as to which type of communications you'd like to receive from us. If you do not wish to be contacted via text, reply stop to a text message from us. There may be exceptions to fulfilling your request as outlined in this Notice, such as for communications to our customers that are important for the use of our Services.We may also email you information regarding updates to the Services and to send information regarding Alkhemist, such as promotions, contests and events. Again, email will not be distributed or shared with third parties and you can opt out of receiving any marketing communications by emailing privacy@bullnocho.com at the time it is distributed, or at the time any individual registers for the Service. If, at any time after registering for information or ordering the Service, you change your mind about receiving information from us send us a request specifying your new choice. Simply send your request to privacy@bullnocho.com. Opting In to Alkhemist Marketing for Non-US CustomersIf you're a customer outside the US, you may need to provide us with your express consent to being contacted by us, or receiving such information from us when you register to use the Services by selecting to opt in. This consent may be necessary in order to receive information regarding updates to the Services and for us to send you information regarding Alkhemist, such as promotions, contests and events.Again, your email will not be distributed or shared with third parties and you can revoke your consent at any time to stop receiving any communication by emailing privacy@bullnocho.com or using the “unsubscribe” option provided in our marketing messages. If, at any time after registering for information or ordering the Service, you change your mind about receiving information from us send us a request specifying your new choice. Simply send your request to privacy@bullnocho.com. Third-Party SitesThe Site contains links to other web sites. Alkhemist is not responsible for the privacy practices or the content of these other web sites. You will need to check the policy statements of these other web sites to understand their policies.California Residents’ Privacy RightsThis part of our Privacy Policy applies to consumers who reside in California. If this section differs from other terms in this Privacy Policy, this section governs for California consumers only.California residents have a right to be informed about our practices regarding the collection, use, disclosure, and sale of personal information. In addition, under the California Consumer Privacy Act (“CCPA”), Consumers have the right to request disclosure and deletion of their personal information, the right not to be discriminated against for exercising one of their California privacy rights, and the right to opt-out of the sale of their personal information by a business. Alkhemist does not sell the Personal Information of California consumers, and we do not discriminate in response to privacy rights requests. In the part of our Privacy Policy titled, “Collection of Personal Data” above, we describe the Personal Information we have collected from consumers in the twelve (12) months preceding the effective date of this Privacy Policy. The information we collect includes the following:
Disclosures of Personal Information for Monetary or Other Valuable Consideration or for Business PurposesWe don't sell consumers’ Personal Information to third parties for monetary value. However, the CCPA broadly defines the word “sale” to include any sharing or disclosing of personal information to another party. To the extent that “sale” is interpreted to include interest based advertising or other data uses described in this Policy, we will comply with applicable law as to those activities. You can read more in our Cookie Notice, including how to exercise your rights to opt out of interest-based advertising.We have disclosed Personal Information in all or substantially all of the categories identified in this section on California Residents’ Privacy Rights for various business purposes and as directed by you in your interactions with our Services. Your California Privacy Rights Under CCPAIf you are a California resident, CCPA provides you the following rights. We will honor requests received to the extent required by law and within the time provided by law. In doing so, where we are acting as a service provider to our customers in our processing of your Personal Information, we may refer requests to access or delete Personal Information to our customers.Right to Access and Information Regarding Personal InformationYou have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
Right to Deletion of Personal InformationYou have the right to request that we delete Personal Information about you that we have collected from you. We will delete such Personal Information except where a legal exception applies or where deletion is technically infeasible. In cases where we do not delete your data as requested, we will notify you of the categories of data we did not delete and why.Right to Opt OutCurrently we do not sell your Personal Information, nor have we sold Personal Information in the preceding twelve months. We will update this Privacy Notice if this ever changes. In that case, you will have the right at any time to direct us not to sell your Personal Information, which is known as your right to opt-out.Right to No DiscriminationWe may not discriminate against you because of your exercise of any of the foregoing rights under the California Consumer Privacy Act, including by:
Requests to Exercise Your RightsYou may request to exercise the foregoing rights by:
Your California Rights Regarding Data Sharing for Direct Marketing PurposesCalifornia consumers also have the right to opt-out of our disclosing personal information about them to third parties for their direct marketing purposes. If you do not want us to disclose information to other companies for their direct marketing purposes, please contact us by any of the ways described in the “How to Contact Us” section above. Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To request a copy of such information, please contact us by any of the ways described in the “How To Contact Us” section above, and we will respond within 30 days as required by law.California law also requires us to disclose how we respond to your Web browser’s “do not track” signals or other mechanisms that provide you the ability to exercise choice regarding the collection of information about your online activities over time and across third-party Web sites or online services. We are also required to disclose whether other parties may collect information about your online activities over time and across different Websites when you use the Sites. The section of this Privacy Notice on Third Party Advertising and Tracking provides additional information on this topic. Your Rights if You Are an EU, UK or Swiss Data SubjectThis section applies if you are an EU, UK or Swiss data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). The term “Personal Information” as used in this Privacy Notice means “personal data” as defined under Regulation (EU) 2016/679 (General Data Protection Regulation, or “GDPR”).Under GDPR, Alkhemist is both a “Controller” and a “Processor”. Alkhemist is the Controller of Personal Information you provide to us about yourself as a customer or when requesting information about our products and services. For data you provide to Alkhemist or request that we collect as part of using our Services, including but not limited to the Personal Information we collect on behalf of our customers, we are a Processor for our customers, who are the Controllers that determine the purposes and means of the processing of your Personal Information by Alkhemist. Alkhemist is based in the USA. Personal information and data processed by Alkhemist is transferred to our servers in the USA. When transferred, we take all reasonable steps to protect your Personal Information, including encryption during data transit and storage. For more information, see “International Data Transfers” below. How We Use EU Personal InformationFor data for which we are the Controller, we collect and use your Personal Information to respond to your enquiries or provide the products and services that you have purchased or take steps to purchase from Alkhemist, as described previously.For data for which we are the Processor, we do not transfer Personal Information to third parties except to the companies on our list of sub-processors, and then only in order to provide the services requested by our customer. When we are acting as a Processor for a customer, you should contact the customer (as Controller) with any questions you may have about how your Personal Information is being used. If you contact us directly when we are acting as a Processor, we may refer your request to the appropriate customer who is the Controller of your Personal Information. If concerns remain, you may contact our Privacy Team as directed in the “How To Contact Us” section above. We rely on the following legal bases for processing your Personal Information:
Rights of EU, UK and Swiss Data SubjectsSubject to applicable law and reasonable steps that we may take to verify your identity with respect to your requests, you have the following rights in relation to your Personal Information. As noted above, where we are acting as a processor for our customer, we may refer your requests to our customer for response.
Data Subjects may contact us as directed in the “How to Contact Us” section above. International Data TransfersVisiting our Site and Using our Services from Outside of the United StatesOur Site and Services are hosted and managed in the USA, so the Personal Information we process will be transferred to and processed in the USA. The USA may have data protection laws that are different than the laws of your country, but we have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Notice. In particular, regarding the transfer to and processing in the United States of Personal Information from the European Economic Area (EEA) member countries, the United Kingdom (UK) and Switzerland, Alkhemist relies on the Standard Contractual Clauses (SCCs, also known as the EU Model Clauses) to help safeguard such Personal Information and as our lawful transfer mechanism under GDPR. Due to their invalidation in July 2020, Alkhemist has withdrawn its participation in and adherence to the EU-US and Swiss-US Privacy Shield Frameworks, and no longer relies on them to transfer relevant Personal Information to the USA. The SCCs are a set of terms and conditions published by the European Commission (EC), and approved for use by the UK, that apply to Controllers and Processors that transfer Personal Information to countries that are not covered by an adequacy decision, such as the USA. In June 2021, the EC published new SCCs, which will replace the SCCs previously adopted by the EC following a transition period. Alkhemist will use its existing SCCs for international data transfers during the transition period and plans to use the new SCCs when applicable and as required by EC rules. You can learn more about the SCCs here. If there is any conflict between the terms of this Policy and the SCCs, the SCCs will govern. Alkhemist commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union, UK or Swiss individuals with inquiries or complaints regarding this privacy policy are encouraged to first contact Alkhemist at the contact information provided in the “How to Contact Us” section above. You may refer any unresolved privacy or data use concern that we have not addressed satisfactorily to your local data protection authority, and we will work with them to resolve your concern. When Alkhemist transfers Personal Information about EU, UK or Swiss individuals to other third parties, it will do so in accordance with the requirements of GDPR applicable to such transfers, including for onward transfers of Personal Information to third parties in other countries that are not covered by an adequacy decision, such as the USA. In these cases, Alkhemist is potentially liable if such third parties do not provide the same level of protection as GDPR. Retention of EU DataFor information on our data retention practices, see the “Data Retention and Destruction” section below, which applies to Personal Information of EU data subjects.Do Not TrackDo-Not-Track is a public-private initiative, http://www.w3.org/2011/tracking-protection/, that has developed a technical “flag” or signal that an end-user may be able to activate within their browser software to notify websites that they do not wish to be “tracked” by 3rd parties as defined by the initiative. The initiative, however, has not reached a consensus as to exactly what technical or other actions those parties receiving the signal should take. As a result, Do-Not-Track has not yet been standardized and most websites, including Alkhemist, do not alter their behavior or change their services when they receive a “do-not-track” flag or signal.Cookies and Advertising TechnologiesWhen you visit our Site, other websites where we advertise Alkhemist’s offerings, or the websites of our customers, we may collect data about your online activities. We use this data to support our own or our customers’ advertising efforts and to provide some of our Services to our customers. To collect this data, we use cookies and other advertising technologies, which may be deployed on our Site, our customers’ websites, and on other websites where we or our customers advertise. These cookies and other technologies can be either our own or provided by third party providers.This section provides additional information about the various technologies that Alkhemist uses to manage the Alkhemist Sites and to deliver ads to you and Services to our customers, including services that collect information when you interact with our customers by phone or on their websites. CookiesWe use cookies to provide functionality to our Sites and also to deliver our Services to our customers. A cookie is a small text file that can be stored on your computer or device when you visit a website, view an advertisement, or interact with an online service. Cookies are used to remember information about you, such as the time you visited a website, your IP address, your browser type, the pages you visit, items you have placed in your shopping cart, and how long you stay on a webpage. A common use of cookies on behalf of our customers is to associate your phone call data with your browsing activity on the customer’s website.To learn more about the cookies and other technologies we serve (including how to opt-out of them), please visit our Cookie Notice. Log filesLike most websites and online services providers, we gather certain information when you visit or interact with our Sites and on our customers’ behalf when you interact with them via our Services. This information is collected automatically and stored in log files. It includes internet protocol (IP) addresses, User Agent, URLs visited on our customers’ websites, and other data that may be accessible through the JavaScript code installed on the customers’ websites.Third Party Advertising ServicesWe may use third parties such as advertising networks, ad exchanges, and analytics service providers to help us serve, optimize and measure the performance of our advertisements across the Internet and mobile applications. You may see our ads on other websites because these third parties’ services may track your online activities across multiple websites, online services and mobile applications over time by collecting information through automated means, such as cookies, and they use this information to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. To learn more about the third party cookies and technologies we use on our Site, see our Cookie Notice.These third party tracking technologies are not controlled by us, even if they use our technology to help store or collect data. Except for the disclosures about third parties in our Cookie notice, statements in this Notice regarding our privacy practices do not apply to the methods for collecting information used by these third-party providers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with the information on their practices and any available opportunity to exercise choice. The relevant third parties’ terms of service, privacy policies, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or providers of tracking technologies or related third parties. You may wish to visit http://www.networkadvertising.org/choices, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. You may also be able to opt-out of receiving interest-based ads by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices/control, the Digital Advertising Alliance of Canada (“DAAC”) at https://youradchoices.ca/en/tools, or the European Digital Advertising Alliance (“EDAA”) website at www.youronlinechoices.com. Similar limitations may apply to the opt-outs provided by these organizations. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options. Opting out of these organizations only means that those members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit their opt-out pages, or you subsequently erase your cookies, use a different device or change web browsers, your opt-outs may not, or may no longer, be effective. Additional information is available on each organization's website accessible by the above links. Google AnalyticsOne of the third party services we use on our Site is Google Analytics, a web analysis service provided by Google, to better understand your use of the Site and Services. Google Analytics collects information such as how often users visit the Websites, what pages they visit and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of our Site, to prepare reports on its activities and share them with other Google services. Google may use the data collected on our Site to contextualize and personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics about your visits to our Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.Google offers an opt-out mechanism for the web available here. Please consult our Cookie Notice below for more information about the types of cookies and tracking technologies that we use on our Site and why, and how to accept and reject them. Correcting & Updating Your InformationConsumers who are not Alkhemist customers can request corrections and updates to your Personal Information by contacting us as directed in the “How To Contact Us” section above.If you are a Alkhemist customer and wish to update your billing information, please log in to your account, click on Billing to update your information. Additionally you can contact Alkhemist support for more assistance with the Personal Information in your account: https://support.bullnocho.com/ To discontinue the Service, please submit a request with Alkhemist support. Alkhemist will respond to your correction or update request within at most 30 days from the date of your request. Data Retention and DestructionWe will retain Personal Information for the period necessary to provide our Services or fulfill the purposes for which it was collected, or as otherwise required by our contracts or by law.When determining how long we should keep data, we consider the length of time we will have a relationship with you and our customers to whom we provide our Services, whether there is a legal obligation that would require us to keep the information for a specified period of time, the reasons why we process your data, and the risk of harm from unauthorized use or disclosure of your Personal Information. We may also anonymize or de-identify Personal Information for research or analytical purposes so that it is no longer associated with you. If data is anonymized or de-identified, we may use this data for as long as we have a legitimate business purpose for such use, without additional notice to you. Where we hold and process Personal Information for a customer as part of our Services, our retention or deletion of data will be subject to that customer’s instructions, and in such cases the customer’s retention and deletion preferences may apply. If a Alkhemist customer cancels their account (or it is terminated for any reason), we make no guarantee that the customer’s data will be retained following termination. For more detailed information about Alkhemist’s Data Retention and Destruction please click here. Confidentiality and SecurityWe restrict access to information collected about our customers and our visitors at our Sites to our employees, our affiliates’ employees, or others who need to know that information to provide services to our visitors or customers or in the course of conducting our normal business operations. We maintain appropriate physical, electronic, and procedural safeguards to protect the information collected via the Sites and Services. We also advise all Alkhemist employees about their responsibility to protect customer data and Personal Information, and we provide them with appropriate guidelines for adhering to our Company’s business ethics standards and policies that relate to information security and privacy.Alkhemist protects its databases with various physical, technical, organizational and procedural measures and we restrict unauthorized access to customer data and Personal Information. While we implement these and other security measures on our sites, please note that 100% security is not always possible. We cannot guarantee that the security measures we have in place to safeguard Personal Information will never be defeated or fail, or that those measures will always be sufficient or effective. Children’s PrivacyOur Services and Sites are not directed at children under 16 years of age (or older where required by law), and we do not knowingly collect or receive Personal Information from them. If we learn that we have received Personal Information from a child whose age requires parental consent for processing, we will make commercially reasonable efforts to remove such data from our Services. If you believe that we have received Personal Information from a child whose age requires parental consent, you may contact us as directed in the “How To Contact Us” section above.Social Media Platforms and WebsitesAny information, communications, or material of any type or nature that you submit to any Alkhemist pages or sites contained on a social media platform or website such as Facebook or Twitter, by email, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at your own risk and without any expectation of privacy. Alkhemist cannot control the actions of other users of any social media platform or website and we are therefore not responsible for any content or Submissions contained on such sites and platforms. By visiting any of our pages or sites that are contained on a social media platform or website, you are representing and warranting to Alkhemist that you have reviewed the applicable privacy policy and terms of use of such platform or website and that you will abide by all such provisions contained therein.Additionally, in the event that any one of the Sites offers a message board or any other interactive or social-type feature on a website administered directly by us, please be aware that these areas may allow you to publicly post, and share with other users, certain messages, content, or other information (e.g., stories, pictures, ingredients, tips, etc.). Although we may take certain precautions to protect those who use these areas of the Alkhemist’s Sites, we encourage you to be wary of giving out any personal information in such public forums. The information you post can be collected and used by people you don’t know. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post. Your use of these features is fully at your own risk. Cookie NoticeA cookie is a small piece of data (text file) that a website — when visited by a user — asks your browser to store on your device in order to remember information about you, such as your language preference, the contents of a shopping cart, or login information. When you visit our Site, the cookies we set on your browser or device are called first party cookies. We also use third party cookies — which are cookies from a domain different than the domain of the website you are visiting — for our advertising and marketing efforts. See the “Cookies and Advertising Technologies” section or our Privacy Notice for more information on how we use cookies.More specifically, we use cookies and other tracking technologies for the following purposes:
Cookies and technologies deployed through our ServicesIf a Alkhemist customer elects to use our JavaScript tool on the customer’s website, the JavaScript will allow the Customer’s website to use certain functionality offered by Alkhemist through the Services, such as the ability to associate your calls with the customer and your activity on the customer’s website. The specific functionality employed on a customer’s website depends on the particular features of the Services that the customer chooses to use. You should therefore review the relevant Customer’s privacy notice and cookie disclosures for further information about the specific types of cookies and other tracking technologies used on the customer’s website and for instructions on how to opt-out or manage your preferences regarding these features of our Services.Updates and Notice of Material Change in the Use of Your Personal InformationWe may update this Privacy Notice and Cookie Notice from time-to-time in our sole discretion. It is your responsibility to review this Privacy Notice for any changes each time that you use the Sites and Services. |
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Privacy Notice
Last Updated: September 2023
This Privacy Notice (“Privacy Notice” or “Notice”) explains the privacy practices of Alkhemist LLC. (“Alkhemist”, “we” or “our”). It describes the ways in which we collect, use (and don’t use), and disclose or sell the information we receive from you, including from our business customers who use our services to interact with you as well as information we receive via our websites (such as bullnocho.com), which we define and describe in this Notice. Our website is referred to collectively in this Notice as the “Sites.” Your ConsentBy using the Sites and Services (as defined below), you consent to the terms of this Privacy Notice. If you do not agree to the terms and conditions of this Privacy Notice, including having your “Personal Information” used in any of the ways described in this Privacy Notice, then do not provide us with your information. If you don’t provide us with your information you may not be able to use certain parts or features of the Sites or the Services.Use of the Sites and Services by you following our posting of a new Privacy Notice on our Sites constitutes your acceptance of the Privacy Notice as modified. In the event we materially change the way in which we use your Personal Information, where required by law we will provide you with notice and ask you to affirmatively accept these material changes. This Privacy Notice applies to all of Alkhemist’s Services. This Privacy Notice is incorporated as part of Alkhemist’s Terms of Use, which apply to your use of the Site and Services. How to Contact UsIf you have any questions about this Privacy Notice, please contact us by emailing privacy@bullnocho.com. You can also contact us by phone at +1 323-591-5505.Description of Our ServicesThe Alkhemist “Services” consist of online, offline and mobile offerings that help our customers track and optimize their call services, including software that can track and record customer calls and that give our customers the ability to use online communication for measuring marketing campaigns, improving customer service, and improving sales performance. Our services may change and be updated from time to time, and further details on our services can be found at www.bullnocho.com/services/.Collection of Personal InformationWhen you register on our Sites or use our Sites or Services, we collect your Personal Information. In this Privacy Notice, the term “Personal Information” refers to information that tells us specifically who you are, such as your name, phone number, email, and postal address, as well as other data associated with you that is deemed to be personal information under the privacy laws of different states or countries. Privacy laws may refer to such information as, for example, “personal data” (UK and EU), “personally identifiable information” (US FTC regulations and various state laws), or “personal information” (California privacy laws). We use Personal Information to refer to all of these terms.Alkhemist collects the information on the callers that call our business customers through the dedicated phone numbers that our business customers have purchased through Alkhemist (or numbers our business customers have requested be ported into Alkhemist from another provider). This information includes: (1) the caller’s phone number; (2) the name displayed on the Caller ID (when available); (3) call recordings and transcripts of calls you place to us or to our customers when using our Services; and (4) other data that may be correlated through our business customer’s data sources (for example, customer data from CRM systems), personal data sources (for example, social contacts and email inboxes), and third party data services (for example, White Pages, Contactive, FullContact). The data is collected in order to display relevant caller information related to an incoming phone call. With respect to our use of data collected from third party data services, the transmission of such data is encrypted using TLS encryption and all data cached is deleted and is not stored by Alkhemist for any longer than necessary for business purposes. We do not share this data outside of the Services. We may use this data to increase the accuracy of caller information and provide more specific information to our customers regarding the call location, to describe the types of businesses that engage with our customers and to determine call histories for analytics purposes. We also collect information on our customers’ website visitors via our JavaScript, as described in more detail in our Cookie Notice. This information includes IP address, User Agent, URLs visited on our customers’ websites, and other data that may be accessible through the JavaScript code installed on the customers’ websites. We use various in-house and third-party analytics tools to analyze the activity of our own customers as they use our Sites and Services. You may opt out of providing your Personal Information by not entering it when asked or by following the instructions provided elsewhere in this Privacy Notice and our Cookie Notice. How We Use Your Personal InformationPersonal information you provide to Alkhemist or our customers who use our Services to interact with you may be used to:
Disclosures and Transfers of Personal InformationWe do not share with or disclose Personal Information to third parties, except when one or more of the following conditions is true:
Opting Out of Alkhemist Marketing in the United StatesYou may opt out of being contacted by us, or receiving such information from us, at any time by sending an email to privacy@bullnocho.com. Current customers can either send an email to privacy@bullnocho.com or submit a ticket through https://support.bullnocho.com/. You may be able to stop receiving some marketing communications, such as emails, by updating your preferences as to which type of communications you'd like to receive from us. If you do not wish to be contacted via text, reply stop to a text message from us. There may be exceptions to fulfilling your request as outlined in this Notice, such as for communications to our customers that are important for the use of our Services.We may also email you information regarding updates to the Services and to send information regarding Alkhemist, such as promotions, contests and events. Again, email will not be distributed or shared with third parties and you can opt out of receiving any marketing communications by emailing privacy@bullnocho.com at the time it is distributed, or at the time any individual registers for the Service. If, at any time after registering for information or ordering the Service, you change your mind about receiving information from us send us a request specifying your new choice. Simply send your request to privacy@bullnocho.com. Opting In to Alkhemist Marketing for Non-US CustomersIf you're a customer outside the US, you may need to provide us with your express consent to being contacted by us, or receiving such information from us when you register to use the Services by selecting to opt in. This consent may be necessary in order to receive information regarding updates to the Services and for us to send you information regarding Alkhemist, such as promotions, contests and events.Again, your email will not be distributed or shared with third parties and you can revoke your consent at any time to stop receiving any communication by emailing privacy@bullnocho.com or using the “unsubscribe” option provided in our marketing messages. If, at any time after registering for information or ordering the Service, you change your mind about receiving information from us send us a request specifying your new choice. Simply send your request to privacy@bullnocho.com. Third-Party SitesThe Site contains links to other web sites. Alkhemist is not responsible for the privacy practices or the content of these other web sites. You will need to check the policy statements of these other web sites to understand their policies.California Residents’ Privacy RightsThis part of our Privacy Policy applies to consumers who reside in California. If this section differs from other terms in this Privacy Policy, this section governs for California consumers only.California residents have a right to be informed about our practices regarding the collection, use, disclosure, and sale of personal information. In addition, under the California Consumer Privacy Act (“CCPA”), Consumers have the right to request disclosure and deletion of their personal information, the right not to be discriminated against for exercising one of their California privacy rights, and the right to opt-out of the sale of their personal information by a business. Alkhemist does not sell the Personal Information of California consumers, and we do not discriminate in response to privacy rights requests. In the part of our Privacy Policy titled, “Collection of Personal Data” above, we describe the Personal Information we have collected from consumers in the twelve (12) months preceding the effective date of this Privacy Policy. The information we collect includes the following:
Disclosures of Personal Information for Monetary or Other Valuable Consideration or for Business PurposesWe don't sell consumers’ Personal Information to third parties for monetary value. However, the CCPA broadly defines the word “sale” to include any sharing or disclosing of personal information to another party. To the extent that “sale” is interpreted to include interest based advertising or other data uses described in this Policy, we will comply with applicable law as to those activities. You can read more in our Cookie Notice, including how to exercise your rights to opt out of interest-based advertising.We have disclosed Personal Information in all or substantially all of the categories identified in this section on California Residents’ Privacy Rights for various business purposes and as directed by you in your interactions with our Services. Your California Privacy Rights Under CCPAIf you are a California resident, CCPA provides you the following rights. We will honor requests received to the extent required by law and within the time provided by law. In doing so, where we are acting as a service provider to our customers in our processing of your Personal Information, we may refer requests to access or delete Personal Information to our customers.Right to Access and Information Regarding Personal InformationYou have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:
Right to Deletion of Personal InformationYou have the right to request that we delete Personal Information about you that we have collected from you. We will delete such Personal Information except where a legal exception applies or where deletion is technically infeasible. In cases where we do not delete your data as requested, we will notify you of the categories of data we did not delete and why.Right to Opt OutCurrently we do not sell your Personal Information, nor have we sold Personal Information in the preceding twelve months. We will update this Privacy Notice if this ever changes. In that case, you will have the right at any time to direct us not to sell your Personal Information, which is known as your right to opt-out.Right to No DiscriminationWe may not discriminate against you because of your exercise of any of the foregoing rights under the California Consumer Privacy Act, including by:
Requests to Exercise Your RightsYou may request to exercise the foregoing rights by:
Your California Rights Regarding Data Sharing for Direct Marketing PurposesCalifornia consumers also have the right to opt-out of our disclosing personal information about them to third parties for their direct marketing purposes. If you do not want us to disclose information to other companies for their direct marketing purposes, please contact us by any of the ways described in the “How to Contact Us” section above. Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To request a copy of such information, please contact us by any of the ways described in the “How To Contact Us” section above, and we will respond within 30 days as required by law.California law also requires us to disclose how we respond to your Web browser’s “do not track” signals or other mechanisms that provide you the ability to exercise choice regarding the collection of information about your online activities over time and across third-party Web sites or online services. We are also required to disclose whether other parties may collect information about your online activities over time and across different Websites when you use the Sites. The section of this Privacy Notice on Third Party Advertising and Tracking provides additional information on this topic. Your Rights if You Are an EU, UK or Swiss Data SubjectThis section applies if you are an EU, UK or Swiss data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). The term “Personal Information” as used in this Privacy Notice means “personal data” as defined under Regulation (EU) 2016/679 (General Data Protection Regulation, or “GDPR”).Under GDPR, Alkhemist is both a “Controller” and a “Processor”. Alkhemist is the Controller of Personal Information you provide to us about yourself as a customer or when requesting information about our products and services. For data you provide to Alkhemist or request that we collect as part of using our Services, including but not limited to the Personal Information we collect on behalf of our customers, we are a Processor for our customers, who are the Controllers that determine the purposes and means of the processing of your Personal Information by Alkhemist. Alkhemist is based in the USA. Personal information and data processed by Alkhemist is transferred to our servers in the USA. When transferred, we take all reasonable steps to protect your Personal Information, including encryption during data transit and storage. For more information, see “International Data Transfers” below. How We Use EU Personal InformationFor data for which we are the Controller, we collect and use your Personal Information to respond to your enquiries or provide the products and services that you have purchased or take steps to purchase from Alkhemist, as described previously.For data for which we are the Processor, we do not transfer Personal Information to third parties except to the companies on our list of sub-processors, and then only in order to provide the services requested by our customer. When we are acting as a Processor for a customer, you should contact the customer (as Controller) with any questions you may have about how your Personal Information is being used. If you contact us directly when we are acting as a Processor, we may refer your request to the appropriate customer who is the Controller of your Personal Information. If concerns remain, you may contact our Privacy Team as directed in the “How To Contact Us” section above. We rely on the following legal bases for processing your Personal Information:
Rights of EU, UK and Swiss Data SubjectsSubject to applicable law and reasonable steps that we may take to verify your identity with respect to your requests, you have the following rights in relation to your Personal Information. As noted above, where we are acting as a processor for our customer, we may refer your requests to our customer for response.
Data Subjects may contact us as directed in the “How to Contact Us” section above. International Data TransfersVisiting our Site and Using our Services from Outside of the United StatesOur Site and Services are hosted and managed in the USA, so the Personal Information we process will be transferred to and processed in the USA. The USA may have data protection laws that are different than the laws of your country, but we have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Notice. In particular, regarding the transfer to and processing in the United States of Personal Information from the European Economic Area (EEA) member countries, the United Kingdom (UK) and Switzerland, Alkhemist relies on the Standard Contractual Clauses (SCCs, also known as the EU Model Clauses) to help safeguard such Personal Information and as our lawful transfer mechanism under GDPR. Due to their invalidation in July 2020, Alkhemist has withdrawn its participation in and adherence to the EU-US and Swiss-US Privacy Shield Frameworks, and no longer relies on them to transfer relevant Personal Information to the USA. The SCCs are a set of terms and conditions published by the European Commission (EC), and approved for use by the UK, that apply to Controllers and Processors that transfer Personal Information to countries that are not covered by an adequacy decision, such as the USA. In June 2021, the EC published new SCCs, which will replace the SCCs previously adopted by the EC following a transition period. Alkhemist will use its existing SCCs for international data transfers during the transition period and plans to use the new SCCs when applicable and as required by EC rules. You can learn more about the SCCs here. If there is any conflict between the terms of this Policy and the SCCs, the SCCs will govern. Alkhemist commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union, UK or Swiss individuals with inquiries or complaints regarding this privacy policy are encouraged to first contact Alkhemist at the contact information provided in the “How to Contact Us” section above. You may refer any unresolved privacy or data use concern that we have not addressed satisfactorily to your local data protection authority, and we will work with them to resolve your concern. When Alkhemist transfers Personal Information about EU, UK or Swiss individuals to other third parties, it will do so in accordance with the requirements of GDPR applicable to such transfers, including for onward transfers of Personal Information to third parties in other countries that are not covered by an adequacy decision, such as the USA. In these cases, Alkhemist is potentially liable if such third parties do not provide the same level of protection as GDPR. Retention of EU DataFor information on our data retention practices, see the “Data Retention and Destruction” section below, which applies to Personal Information of EU data subjects.Do Not TrackDo-Not-Track is a public-private initiative, http://www.w3.org/2011/tracking-protection/, that has developed a technical “flag” or signal that an end-user may be able to activate within their browser software to notify websites that they do not wish to be “tracked” by 3rd parties as defined by the initiative. The initiative, however, has not reached a consensus as to exactly what technical or other actions those parties receiving the signal should take. As a result, Do-Not-Track has not yet been standardized and most websites, including Alkhemist, do not alter their behavior or change their services when they receive a “do-not-track” flag or signal.Cookies and Advertising TechnologiesWhen you visit our Site, other websites where we advertise Alkhemist’s offerings, or the websites of our customers, we may collect data about your online activities. We use this data to support our own or our customers’ advertising efforts and to provide some of our Services to our customers. To collect this data, we use cookies and other advertising technologies, which may be deployed on our Site, our customers’ websites, and on other websites where we or our customers advertise. These cookies and other technologies can be either our own or provided by third party providers.This section provides additional information about the various technologies that Alkhemist uses to manage the Alkhemist Sites and to deliver ads to you and Services to our customers, including services that collect information when you interact with our customers by phone or on their websites. CookiesWe use cookies to provide functionality to our Sites and also to deliver our Services to our customers. A cookie is a small text file that can be stored on your computer or device when you visit a website, view an advertisement, or interact with an online service. Cookies are used to remember information about you, such as the time you visited a website, your IP address, your browser type, the pages you visit, items you have placed in your shopping cart, and how long you stay on a webpage. A common use of cookies on behalf of our customers is to associate your phone call data with your browsing activity on the customer’s website.To learn more about the cookies and other technologies we serve (including how to opt-out of them), please visit our Cookie Notice. Log filesLike most websites and online services providers, we gather certain information when you visit or interact with our Sites and on our customers’ behalf when you interact with them via our Services. This information is collected automatically and stored in log files. It includes internet protocol (IP) addresses, User Agent, URLs visited on our customers’ websites, and other data that may be accessible through the JavaScript code installed on the customers’ websites.Third Party Advertising ServicesWe may use third parties such as advertising networks, ad exchanges, and analytics service providers to help us serve, optimize and measure the performance of our advertisements across the Internet and mobile applications. You may see our ads on other websites because these third parties’ services may track your online activities across multiple websites, online services and mobile applications over time by collecting information through automated means, such as cookies, and they use this information to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. To learn more about the third party cookies and technologies we use on our Site, see our Cookie Notice.These third party tracking technologies are not controlled by us, even if they use our technology to help store or collect data. Except for the disclosures about third parties in our Cookie notice, statements in this Notice regarding our privacy practices do not apply to the methods for collecting information used by these third-party providers and others or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with the information on their practices and any available opportunity to exercise choice. The relevant third parties’ terms of service, privacy policies, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or providers of tracking technologies or related third parties. You may wish to visit http://www.networkadvertising.org/choices, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. You may also be able to opt-out of receiving interest-based ads by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices/control, the Digital Advertising Alliance of Canada (“DAAC”) at https://youradchoices.ca/en/tools, or the European Digital Advertising Alliance (“EDAA”) website at www.youronlinechoices.com. Similar limitations may apply to the opt-outs provided by these organizations. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options. Opting out of these organizations only means that those members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit their opt-out pages, or you subsequently erase your cookies, use a different device or change web browsers, your opt-outs may not, or may no longer, be effective. Additional information is available on each organization's website accessible by the above links. Google AnalyticsOne of the third party services we use on our Site is Google Analytics, a web analysis service provided by Google, to better understand your use of the Site and Services. Google Analytics collects information such as how often users visit the Websites, what pages they visit and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of our Site, to prepare reports on its activities and share them with other Google services. Google may use the data collected on our Site to contextualize and personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics about your visits to our Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.Google offers an opt-out mechanism for the web available here. Please consult our Cookie Notice below for more information about the types of cookies and tracking technologies that we use on our Site and why, and how to accept and reject them. Correcting & Updating Your InformationConsumers who are not Alkhemist customers can request corrections and updates to your Personal Information by contacting us as directed in the “How To Contact Us” section above.If you are a Alkhemist customer and wish to update your billing information, please log in to your account, click on Billing to update your information. Additionally you can contact Alkhemist support for more assistance with the Personal Information in your account: https://support.bullnocho.com/ To discontinue the Service, please submit a request with Alkhemist support. Alkhemist will respond to your correction or update request within at most 30 days from the date of your request. Data Retention and DestructionWe will retain Personal Information for the period necessary to provide our Services or fulfill the purposes for which it was collected, or as otherwise required by our contracts or by law.When determining how long we should keep data, we consider the length of time we will have a relationship with you and our customers to whom we provide our Services, whether there is a legal obligation that would require us to keep the information for a specified period of time, the reasons why we process your data, and the risk of harm from unauthorized use or disclosure of your Personal Information. We may also anonymize or de-identify Personal Information for research or analytical purposes so that it is no longer associated with you. If data is anonymized or de-identified, we may use this data for as long as we have a legitimate business purpose for such use, without additional notice to you. Where we hold and process Personal Information for a customer as part of our Services, our retention or deletion of data will be subject to that customer’s instructions, and in such cases the customer’s retention and deletion preferences may apply. If a Alkhemist customer cancels their account (or it is terminated for any reason), we make no guarantee that the customer’s data will be retained following termination. For more detailed information about Alkhemist’s Data Retention and Destruction please click here. Confidentiality and SecurityWe restrict access to information collected about our customers and our visitors at our Sites to our employees, our affiliates’ employees, or others who need to know that information to provide services to our visitors or customers or in the course of conducting our normal business operations. We maintain appropriate physical, electronic, and procedural safeguards to protect the information collected via the Sites and Services. We also advise all Alkhemist employees about their responsibility to protect customer data and Personal Information, and we provide them with appropriate guidelines for adhering to our Company’s business ethics standards and policies that relate to information security and privacy.Alkhemist protects its databases with various physical, technical, organizational and procedural measures and we restrict unauthorized access to customer data and Personal Information. While we implement these and other security measures on our sites, please note that 100% security is not always possible. We cannot guarantee that the security measures we have in place to safeguard Personal Information will never be defeated or fail, or that those measures will always be sufficient or effective. Children’s PrivacyOur Services and Sites are not directed at children under 16 years of age (or older where required by law), and we do not knowingly collect or receive Personal Information from them. If we learn that we have received Personal Information from a child whose age requires parental consent for processing, we will make commercially reasonable efforts to remove such data from our Services. If you believe that we have received Personal Information from a child whose age requires parental consent, you may contact us as directed in the “How To Contact Us” section above.Social Media Platforms and WebsitesAny information, communications, or material of any type or nature that you submit to any Alkhemist pages or sites contained on a social media platform or website such as Facebook or Twitter, by email, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at your own risk and without any expectation of privacy. Alkhemist cannot control the actions of other users of any social media platform or website and we are therefore not responsible for any content or Submissions contained on such sites and platforms. By visiting any of our pages or sites that are contained on a social media platform or website, you are representing and warranting to Alkhemist that you have reviewed the applicable privacy policy and terms of use of such platform or website and that you will abide by all such provisions contained therein.Additionally, in the event that any one of the Sites offers a message board or any other interactive or social-type feature on a website administered directly by us, please be aware that these areas may allow you to publicly post, and share with other users, certain messages, content, or other information (e.g., stories, pictures, ingredients, tips, etc.). Although we may take certain precautions to protect those who use these areas of the Alkhemist’s Sites, we encourage you to be wary of giving out any personal information in such public forums. The information you post can be collected and used by people you don’t know. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post. Your use of these features is fully at your own risk. Cookie NoticeA cookie is a small piece of data (text file) that a website — when visited by a user — asks your browser to store on your device in order to remember information about you, such as your language preference, the contents of a shopping cart, or login information. When you visit our Site, the cookies we set on your browser or device are called first party cookies. We also use third party cookies — which are cookies from a domain different than the domain of the website you are visiting — for our advertising and marketing efforts. See the “Cookies and Advertising Technologies” section or our Privacy Notice for more information on how we use cookies.More specifically, we use cookies and other tracking technologies for the following purposes:
Cookies and technologies deployed through our ServicesIf a Alkhemist customer elects to use our JavaScript tool on the customer’s website, the JavaScript will allow the Customer’s website to use certain functionality offered by Alkhemist through the Services, such as the ability to associate your calls with the customer and your activity on the customer’s website. The specific functionality employed on a customer’s website depends on the particular features of the Services that the customer chooses to use. You should therefore review the relevant Customer’s privacy notice and cookie disclosures for further information about the specific types of cookies and other tracking technologies used on the customer’s website and for instructions on how to opt-out or manage your preferences regarding these features of our Services.Updates and Notice of Material Change in the Use of Your Personal InformationWe may update this Privacy Notice and Cookie Notice from time-to-time in our sole discretion. It is your responsibility to review this Privacy Notice for any changes each time that you use the Sites and Services. |
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