1. What is “Personal Data”?
2. Information Collected
3. How We Collect and Process Information
4. Purposes for Collecting Your Information
5. Sharing of Information Collected & Location of Personal Data
6. Individual Rights
7. Security
8. Data Retention and Storage
9. Purchases by Minors / Children
10. Contact
11. Policy Updates and Modifications
12. Country-Specific Regulations
United States
Brazil
Canada
Costa Rica
EU, UK and Switzerland
India
Japan
Nigeria
Peru
South Africa
South Korea
Turkey
The term “Personal Data” refers to information that does or is capable of identifying you as an individual. Personal Data may include the following: name, address, date of birth, and contact data (i.e. email address, telephone number and employer name). No sensitive information will be collected regarding the user.
We may also collect information that is related to you but that does not personally identify you (“Non-Personal Data”). Non-Personal Data includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) to remove or obscure any Personal Data.
The type of information we collect or process from or about you will depend on how you and/or your organization interacts with BITE.
Automatic Information: We may collect Technical Information about you when you visit our websites (bitedata.io and nuborders.com), which your web browser automatically sends whenever you visit a website on the Internet. “Technical Information” is information that does not, by itself, identify a specific individual but which could be used to indirectly identify you. Our servers automatically record Technical Information, which may include your Internet Protocol (“IP”) address, browser type, browser language, and the date and time of your request.
Information you give us: When you sign up for the BITE application, we will ingest and store information about you and your organization, including your name, company, and email address.
Information from third party sources: The data in BITE includes personally identifiable information such as name and address, for entities listed on official government lists, publicly available / open source trade and risk records, as well as third party data sets curated by entities that collect data on people, organizations and companies that are relevant to the trade, supply chain and security domain.When we receive Personal Data from customers who originate or retain ownership of such Personal Data, we are a data processor and our Terms and Conditions (including any data protection agreements) with our Customers will apply to the processing of such Personal Data.
We collect Personal Data about you when you submit information through our websites. Examples include requests for product information; registering for access to the BITE application, for BITE reports, newsletters or webcasts; or entering promotions.
We use pixel tags and cookies in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that’s embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on a BITE website. We use tools like pixel tags and cookies so that we can determine interest in particular topics and measure and improve the effectiveness of our communications.
Log files record website activity on our services and enable us to gather statistics about our users’ browsing habits. These entries help BITE determine how many and how often users have accessed or used our services, which pages they’ve visited, and other similar data.
We may collect information about your use of the websites through cookies and similar technologies. A “cookie” is text that we store through your computer’s web browser so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the websites.
Our websites use the following types of cookies for the purposes set out below:
These cookies are essential to provide you with services available through our websites and to enable you to use some of its features, e.g., to allow you to log in to secure areas of our websites. Without these cookies, the services that you have requested cannot be provided.
These cookies allow our websites to remember choices you make when you use our website, such as remembering your user preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our website.
These cookies are used to collect information about traffic to our website. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. We use this information to help operate our website more efficiently, to gather broad demographic information and to monitor the level of activity on our website.
We may use Google Analytics and other third party analytics services for this purpose. Google Analytics uses its own cookies. It is only used to improve how our website works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
These cookies are used when you share information using a social media sharing button or “like” button on our website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.
We will collect information on all users when they access the application. This will be standard information (Name, User Name, Password, Team Name, Team position).
The BITE application includes personally identifiable data that we receive from third party sources, in the form of sanctions lists, watchlists and other lists that apply to the domain of trade risk. These are open-source lists and BITE does not control the source data included in these lists. The BITE application will also include PII as it relates to entities (companies, people and organizations), that we identify in open-source data through our own research. These entities typically are associated with trade risk and are useful to BITE users that wish to reduce risk in their supply chain.
Our websites may contain social media features. These features may collect your IP address, the pages visited on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the organization providing it.
Our websites, products or services may link to third party web websites, and BITE is not responsible for any Personal Data collected by these third-party websites. Information collected is governed through the third party’s privacy policy. Any interactions you have with these web websites, or any services or applications they offer, are beyond our control.
In order to purchase BITE subscriptions, we will collect payment information including but not limited to Cardholder or Bank account owner name, address, account details, billing address and more, related to payment processing. This data will reside in both the BITE platform databases and the payment merchant’s databases (Stripe - https://stripe.com/)
For all of the above, data is processed as follows: Data is processed using the BITE servers in our Amazon Web Services (AWS) US enclave and then stored in a BITE database in the Cloud.For publicly accessible websites, cookie data is also stored locally in a user’s browser, as well as through Google analytics services.
We will only process and use your Personal Data in accordance with applicable data protection and privacy laws. Use of personal data include the following on BITE:
We may use Non-Personal Data for any reason and may share such information freely with third parties.
BITE gives you choices about the ways we collect, use, and share your Personal Data. You can choose what contact will be stored in your account and preferences. However, if you choose not to provide certain details, some of your experiences with us may be affected.
We do not use your Personal Data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
If you would like to know what Personal Data we hold about you, you may submit a request to us by using Legal_Compliance@nuborders.com. We will supply Personal Data about you that we hold in our own files within the reasonable timeframes stipulated by law. Please note that some requests may be subject to a reasonable fee.
We will not rent or sell user-related Personal Data to others but may disclose Personal Data with contracted third-party vendors and service providers (including cloud service providers) that work with BITE and are contractually bound by confidentiality obligations. We will only share Personal Data with these vendors and service providers to help us provide a product or service.
We store data about our customers and users in the United States. Customer information, including Personal Data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside.
If we sell any part of our operations, we may transfer Personal Data in connection with the sale. If a sale does occur, we will attempt to notify you of the disclosure of your Personal Data.
We reserve the right to disclose information required by law, litigation, or as a matter of national security to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise required by applicable law. We may also need to disclose Personal Data in the event of an emergency that threatens an individual’s life, health, or security.
For the data that we collect on individual users who access our website and register for and use the BITE application, the following apply:
Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive Personal Data; (iv) any new processing of your Personal Data that we may carry out beyond the original purpose; or (v) the transfer of your Personal Data. Please note that your use of the websites may be impacted upon opt-out.
Access. You may access the data we hold about you at any time by contacting us directly.
Amend. You can also contact us to update or correct any inaccuracies in your Personal Data.
Move. Your data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
Delete. You can request that we erase your Personal Data. This can include personal data that we list on the BITE application based on analysis our team performs. For example, if we list your personal data as being part of a specific BITE list, you may request to have data removed. Our team will review the request and follow applicable laws to remove your data from our website and/or application.
Update: If you want to add, update, or delete information related to your account, you can do so from the BITE application at https://app.bitedata.io. When you update or delete any information, we usually keep a copy of the prior version for our records.
Cookies Preferences: You can change your cookie preferences on BITE sites at any time by clicking Cookie Preferences in the footer of the bitedata.io site. You can also manage cookies through your browser settings. The "Help" feature on most browsers and devices will tell you how to remove cookies from your device, how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
Security of all information is of the utmost importance for us. We use reasonable administrative, technical and physical safeguards to protect the security of your Personal Data from unauthorized disclosure. We also try to ensure that only necessary people and third parties have access to Personal Data. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of Personal Data and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of Personal Data that may affect you so that you can take the appropriate actions for the due protection of your rights. We also review our security procedures periodically to consider appropriate new technology and updated methods.
We require that our third-party service providers agree to keep all confidential information we share with them and to use the information only to perform their obligations in the agreements we have in place with them. While we provide these third parties with no more information than is necessary to perform the function for which we engaged them, any information that you provide to these third parties independently is subject to their respective privacy policies and practices.
We retain your information for business purposes, for as long as your account is active, and/or as long as is reasonably necessary to provide you with our products and services. BITE will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time.
We don’t provide BITE offerings for purchase by children. If you’re under 18, you may use BITE offerings only with the involvement of a parent or guardian.
Our data protection officer is our Chief Privacy Officer. If you have any questions, concerns, or suggestions regarding this Privacy Policy, or would like to reach our data protection officer, please contact us by legal_compliance@nuborders.com.
Address: 1037 Pleasant St. Bridgewater, MA 02324.
Names and addresses for relevant parties are as follows:
Privacy Officer: Thariq Kara
Head of Compliance and Contracts: Shawn Corcoran
Chief Counsel: Edward Gildea
We may review and update this Privacy Policy related to the BITE platform periodically without prior notice. It is up to the user to ensure they review updated policy documents. Your continued use of our websites after changes have been posted to this Privacy Policy will constitute your acceptance of such changes. In the case of material changes that may adversely affect you, we may notify you directly of changes to this Privacy Policy.
These additional state-specific privacy disclosures, which serve as a Notice at Collection under the California Privacy Rights Act, are required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act and are effective as of June 30, 2023:
If you are a California Resident, the California Consumer Privacy Act of 2018 (“CCPA”) may give you certain rights relating to your personal information. Please visit the California Attorney General’s privacy laws page located here for more information.
At points throughout our website, you may be able to provide your contact information. If you provide your contact information, we will maintain that information until you request that we delete it. If you want us to delete your contact information, please email us from the email address you provided originally. BITE will not discriminate against you for exercising your privacy rights.
We do not sell any Personal Information (as defined in the CCPA) to third parties and have not done so in the previous 12 months.
Please contact us at legal_compliance@nuborders.com to request access to your data records and/or to ask us how we adhere to the CCPA.
Categories of personal information collected. The personal information that we may collect, or may have collected from consumers in the preceding twelve months, are noted in section 3 and 4 of this document.
Your Data Rights. You may have certain data rights under state privacy laws, including to request information about the collection of your personal information by us, to access your personal information in a portable format, and to correct or delete your personal information. If you wish to do any of these things and you are a BITE customer, please contact us at legal_compliance@nuborders.com.
California Privacy Rights Act Sensitive Personal Information Disclosure. The categories of data that we collect and disclose for a business purpose include “sensitive personal information” as defined under the California Privacy Rights Act. We do not use or disclose sensitive personal information for any purpose not expressly permitted by the California Privacy Rights Act.
California Privacy Rights Act Retention Disclosure. We keep your personal information to enable your continued use of NU Borders Services and BITE offerings , for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, as permitted or as may be required by law, or as otherwise communicated to you.
California Privacy Rights Act Non-Discrimination Statement. We will not discriminate against any consumer for exercising their rights under the California Privacy Rights Act.
California Privacy Rights Act, Colorado Privacy Act, Connecticut Data Privacy Act, Virginia Consumer Data Protection Act, and Utah Consumer Privacy Act De-identified Data Disclosure. BITE may use de-identified data in some instances. BITE either maintains such data without attempting to re-identify it or treats such data as personal data subject to applicable law.
Colorado Privacy Act Profiling Disclosure. We do not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under the Colorado Privacy Act.
Data Controller: If BITE contains data on Brazilian entities, please contact us at legal_compliance@nuborders.com to access your data. NU Borders LLC does not maintain active offices in Brazil at this time.
Processing: We process your personal information per Section 3 of this document.
Your Rights. Subject to applicable law, you have the right to:
If you wish to do any of these things and/or request for your personal data to be removed from BITE regardless of whether you are a customer that uses BITE, and you reside in Brazil, please contact us at legal_compliance@nuborders.com. You can also file a complaint with Brazil’s National Data Protection Authority (ANPD) through its official channels.
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Transfers outside of Brazil. When we transfer your personal information outside Brazil, we do so in accordance with the terms of this Privacy Notice and applicable data protection law.
Your Rights. Subject to applicable law, you have the right to:
Ask whether we hold personal information about you and request copies of such personal information and information about how it is processed;
Request that inaccurate personal information is corrected;
Request deletion of personal information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements; and
Lodge a complaint with us regarding our practices related to your personal information.
If you wish to do any of these things and/or request for your personal data to be removed from BITE regardless of whether you are a customer that uses BITE, and you reside in Canada, please contact us at legal_compliance@nuborders.com.
NU Borders LLC does not maintain offices in Canada at this time. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Rights: With respect to data collected and processed NU Borders LLC and the BITE platforms, you have the rights of access, rectification, erasure, restriction, or complaint. When you consent to NU Borders processing your personal information for a specified purpose, you may withdraw your consent at any time and NU Borders will stop any further processing of your data for that purpose.
If you wish to do any of these things and/or request for your personal data to be removed from BITE regardless of whether you are a customer that uses BITE, and you reside in Costa Rica, please contact us at legal_compliance@nuborders.com.
NU Borders LLC does not maintain offices in Costa Rica at this time. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Controller of Personal Information: NU Borders LLC is the legal entity controlling your data. At this time, NU Borders does not have an office or legal entity represented in the EU, UK or Switzerland. Please reach out to legal_compliance@nuborders.com for further information on NU Borders and BITE platform legal status.
Processing: we process your personal information per Section 3 of document.
Information We Retain After Your Account is Closed: If you decide to terminate your agreement and close your BITE account, we will retain your content for a period of up to 90 days after account closure. Should you wish to receive information from your account during this period, or re-open your account, please email us at legal_compliance@nuborders.com.
After account closure, we may need to keep certain information for an additional period of time for legal and legitimate business purposes. For example, we may retain personal information such as your contact information (e.g., name, email address, physical address) and any invoices that NU Borders has sent to you (e.g., record of purchases, applicable discounts, and tax information) for tax and accounting purposes.
Your Rights. Subject to applicable law, you have the right to:
Should you have any questions on the above, please contact us at legal_compliance@nuborders.com. You can also lodge a complaint with our principal supervisory authority, the Commission Nationale pour la Protection des Données in Luxembourg, or with a local authority.
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Cookies. Please refer to our Cookie notice here: https://www.bitedata.io/cookies-policy
Transfers outside of the EEA. When we transfer your personal information outside the EEA we do so in accordance with the terms of this Privacy Notice and applicable data protection law.
Rights: With respect to data collected and processed NU Borders LLC and the BITE platforms, you have the rights of access, rectification, erasure, restriction, or complaint. When you consent to NU Borders processing your personal information for a specified purpose, you may withdraw your consent at any time and NU Borders will stop any further processing of your data for that purpose.
If you wish to do any of these things and/or request for your personal data to be removed from BITE regardless of whether you are a customer that uses BITE, and you reside in India, please contact us at legal_compliance@nuborders.com. NU Borders LLC does not maintain offices in India at this time. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Rights: With respect to data collected and processed NU Borders LLC and the BITE platforms, you have the rights of access, rectification, erasure, restriction, or complaint. When you consent to NU Borders processing your personal information for a specified purpose, you may withdraw your consent at any time and NU Borders will stop any further processing of your data for that purpose.
If you wish to do any of these things and/or request for your personal data to be removed from BITE regardless of whether you are a customer that uses BITE, and you reside in Japan, please contact us at legal_compliance@nuborders.com. NU Borders LLC does not maintain offices in Japan at this time. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Use of Personal Information: We jointly use your personal information for such purposes as described in this Privacy Notice with partner companies, customers and other global entities that either are subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice. Jointly used personal information includes personal information described under “Personal Information We Collect” and “Example of Information Collected” above. NU Borders LLC is the business operator primarily responsible for managing jointly used personal information.
We share personal information with third parties only to the extent described under “How We Share Personal Information” above and in accordance with the Act on Protection of Personal Information.
When we share your personal information with third parties outside of Japan, we require the recipients to adopt personal information security measures to protect your personal information.
Please see here for information on the countries where third parties may be located, and the applicable data privacy laws and data protection systems in these countries: https://www.cas.go.jp/jp/seisaku/hourei/data/APPI.pdf
Rights: With respect to data collected and processed NU Borders LLC and the BITE platforms, you have the rights of access, rectification, erasure, restriction, or complaint. When you consent to NU Borders processing your personal information for a specified purpose, you may withdraw your consent at any time and NU Borders will stop any further processing of your data for that purpose.
If you wish to do any of these things and/or request for your personal data to be removed from BITE regardless of whether you are a customer that uses BITE, and you reside in Nigeria, please contact us at legal_compliance@nuborders.com. NU Borders LLC does not maintain offices in Nigeria at this time. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Additionally you may:
If you wish to address any of the following and you are in Nigeria, please contact us at legal_compliance@nuborders.com.
You can also file a complaint with Nigeria’s National Information Technology Development Agency through its official channels.
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Rights: With respect to data collected and processed NU Borders LLC and the BITE platforms, you have the rights of access, rectification, erasure, restriction, or complaint. When you consent to NU Borders processing your personal information for a specified purpose, you may withdraw your consent at any time and NU Borders will stop any further processing of your data for that purpose.
If you wish to do any of these things and/or request for your personal data to be removed from BITE regardless of whether you are a customer that uses BITE, and you reside in Peru, please contact us at legal_compliance@nuborders.com. NU Borders LLC does not maintain offices in Peru at this time. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Additionally you may:
If you wish to address any of the following and you are in Peru, please contact us at legal_compliance@nuborders.com.
You can also file a complaint before the Peruvian National Data Protection Authority through its official channels.
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Rights: With respect to data collected and processed NU Borders LLC and the BITE platforms, you have the rights of access, rectification, erasure, restriction, or complaint. When you consent to NU Borders processing your personal information for a specified purpose, you may withdraw your consent at any time and NU Borders will stop any further processing of your data for that purpose.
If you wish to do any of these things and/or request for your personal data to be removed from BITE regardless of whether you are a customer that uses BITE, and you reside in South Africa, please contact us at legal_compliance@nuborders.com. NU Borders LLC does not maintain offices in South Africa at this time.
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Additionally you may:
If you wish to address any of the following and you are in South Africa, please contact us at legal_compliance@nuborders.com.
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
Rights: With respect to data collected and processed NU Borders LLC and the BITE platforms, you have the rights of access, rectification, erasure, restriction, or complaint. When you consent to NU Borders processing your personal information for a specified purpose, you may withdraw your consent at any time and NU Borders will stop any further processing of your data for that purpose.
If you wish to do any of these things and/or request for your personal data to be removed from BITE regardless of whether you are a customer that uses BITE, and you reside in South Korda, please contact us at legal_compliance@nuborders.com. NU Borders LLC does not maintain offices in South Korea at this time.
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.
NU Borders does not knowingly collect personal information from children under the age of 14 without the consent of the child's parent or guardian.
NU Borders may share personal information as described in this Privacy Notice, including with affiliates of NU Borders LLC.
NU Borders does not maintain affiliate relationships with any companies in South Korea. This Privacy Notice will be updated should we engage in an affiliate or partnership agreement with a South Korean entity.
Account Deletion: NU Borders will delete your personal information (including after closure of your BITE account) as described in this Privacy Notice. When deleting personal information, we will take standard commercially reasonable measures to make the personal information practically irrecoverable or irreproducible. The specific manner of deletion will depend on the information being deleted, how the information was collected and stored, and your interactions with us. Electronic documents or files containing personal information will be deleted using a technical method that makes recovery or retrieval of such information practically impossible or renders the data no longer personally identifiable. Non-electronic documents or files containing personal information will be shredded, incinerated, or both.
Retention of Personal Information: NU Borders keeps your personal information to enable your continued use of BITE Offerings, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice, as may be required by law (including for tax and accounting purposes as may be required by the Framework Act on National Taxes of Republic of Korea or other laws), or as otherwise communicated to you. How long we retain specific personal information varies depending on the purpose for its use, and we will delete your personal information in accordance with applicable law.
Rights: With respect to data collected and processed NU Borders LLC and the BITE platforms, you have the rights of access, rectification, erasure, restriction, or complaint. When you consent to NU Borders processing your personal information for a specified purpose, you may withdraw your consent at any time and NU Borders will stop any further processing of your data for that purpose.
If you wish to do any of these things and/or request for your personal data to be removed from BITE regardless of whether you are a customer that uses BITE, and you reside in Turkey, please contact us at legal_compliance@nuborders.com. NU Borders LLC does not maintain offices in Turkey at this time. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.