BORIKEN PRIVATE SOCIETY is not as any type of established organization to which everyone can belong, but as a network to congregate only like-minded people, who share the same taste for a first-class lifestyle, exquisiteness for attending exclusive events that can only be accessed by invitation, making friends while traveling, discovering and enjoying the best that Puerto Rico offers. BORIKEN PRIVATE SOCIETY of 644 Fernandez Juncos Avenue, San Juan, Puerto Rico is the data controller (“BPS” or “we”) and we take your privacy seriously. If you have any questions about this policy, we can be reached by email at email@example.com. Alternatively, you can contact us at:
c/o BORIKEN PRIVATE SOCIETY
644 Manuel Fernandez Juncos Ave.,
San Juan, PR 00907
INFORMATION WE HAVE COLLECTED AND MAY COLLECT AND HOW
When you register on our Site, we will collect some personal information from you, such as your name, email address, country of origin, location, occupation, schools attended, photos, social media accounts and other data you upload or enter into your profile. This personal data is entered by you during the application or registration process or shared by you through another social media service, in order to become a member of BPS, apply for membership or other use of the BPS Service. While your credit card number is validated on the Site, your credit card number and payment details are stored exclusively by our third party payment providers and not by us.
We may also collect data about your navigation of the Site on an aggregate basis, such as your Internet Protocol Address (“IP Address”), which is identified and logged automatically in our server log files whenever you navigate the Site, your Internet Service Provider (“ISP”), your login frequency, the pages you visited within the Site, and the Internet browser or device you are using.
When you participate in the Site member offers, complete forms for optional promotions, RSVP for the Site events, or participate in contests, surveys, or beta testing, we may require that you submit certain personal information to the Site, our mobile application or via email. You may also voluntarily provide personal information when you send us an enquiry or support request via email. When you contact us, we keep a record of your communication, and may use third party service providers (e-mail system provider, CRM systems), to help solve any issues you might be facing in the future. When you use BPS, you may share your location data for us to optimize your experience and inform you about other members nearby. You may also share your upcoming events on BPS, as well as interests, data that is shared with us and other members and may be used to suggest other members to connect to you and you to connect to other members.
Surveys are periodically conducted to collect information to help us improve the Site. All information collected through surveys will remain confidential, even if we use a third party to help us conduct the survey, unless otherwise indicated.
Any information you disclose in public areas of the Site may become public information. Please exercise caution when disclosing personal information in these areas. We are not responsible for any use by third parties of personal information disclosed by you in public areas of the Site.
In order to facilitate the fulfillment of privileges for Members, You may authorize BPS to provide private data relevant to privilege redemption to privilege partners in question. Your approval will be requested before such data is exchanged. Any such exchange only happens for the fulfillment of privileges.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of the Site. They include, for example, cookies that enable you to log into secure areas of the Site.
Analytical/performance/statistical cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Site when they are using it. This helps us to improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognize you when you return to the Site. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice city).
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or indicate when a cookie is being sent. You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Site and your user experience may be inferior when navigating our Site.
WHY WE COLLECT INFORMATION
Information collected may be used to provide and improve our products and service of the Site; for billing, identification and authentication purposes; to analyze the Site usage for statistical purposes; to manage and improve our products and the Site; to deliver administrative and informative notices and communications relevant to your use of our products and the Site; for internal market research; for troubleshooting problems; for detecting, protecting against and preventing fraudulent or other criminal activity; for distribution to third party contractors who provide services to us (such as our email server) who are bound by our privacy restrictions or restrictions at least as restrictive as those set forth in this policy; to enforce our Terms of Service.
WITH WHOM WE SHARE
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries for outsourcing purposes (i.e. where such member of our group provides services for and on our behalf).
Partners may sponsor special member offers, promotions, privileges or contests that require you to disclose personal information to benefit from them. We will never disclose private member data, including email addresses, to partners without your prior express consent. Certain partners may require members to opt-in or agree to terms on the partners’ landing pages authorizing us to provide member information to the partner in question. We advise you always to check our partners’ privacy policies before submitting information about yourself.
We may disclose your personal information:
in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
to identify, contact or bring legal action against you if you are violating our Terms of Service or other rules or if we believe you are causing injury or interference with the rights of members, the general public or BPS;
if we or substantially all of our assets are acquired by a third party, in which case personal information held by us will be some of the transferred assets; and
if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements or to protect our rights, property, or safety of our customers, or others.
In the event that you raise a payment dispute and your bank or credit card provider requests data supporting your transaction and use of the BPS Service.
OPTING IN OR OUT OF COMMUNICATIONS
If you supply us with your postal address, you may receive mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please go to your account settings and deselect the relevant boxes or let us know by emailing us at firstname.lastname@example.org.
To ensure removal from any lists, please provide us with your exact name, as it appears in your BPS profile, and address when communicating with us.
WHERE WE STORE/TRANSFER YOUR PERSONAL DATA
DATA RETENTION POLICY
BPS may retain information submitted by you following application/termination/deactivation of your Membership, ensuring that you will benefit from communications, and to allow for (re-)activation of your Membership at a later point in time. If you de-register from all BPS Services, we may retain information submitted by you or collected from you, for such time as is reasonably necessary for backup, archival and/or audit purposes, to prevent fraud or other criminal activity, or prevent violation of our Terms of Service and for such time as may be required by applicable laws.
We will remove personal information by deleting it from our database if required to do so by law. We will also rectify inaccurate personal data concerning you (for both, send e-mail request to email@example.com).
We regularly review the way we collect, store and process information, including physical security measures, in order to protect our systems from any unauthorized access.
All of our services are fully encrypted using SSL.
Access to any personal information is limited to BPS employees, contractors and agents, to the extent relevant to their job duties (such as processing certain information). Anyone with access to private data is bound by strict confidentiality obligations.
NOTIFICATION OF NEW USES
This policy became effective on 1 April 2019.