BNB Ring Privacy Policy
Health is wealth
Introduction
At Hong Kong Faith Technology Group Limited. ("we", "our", "BNB Ring", “BNB Ring”, or "us"), we prioritize your privacy and are committed to protecting the personal and sensitive information you share with us through the bnbring.com and BNB Ring Wellness App. This privacy policy outlines our data collection, usage, sharing, and retention practices, ensuring compliance with international data protection laws.
By using our app, you agree to the terms outlined in this policy. If you do not agree, please discontinue use of the app.
1.Information We Collect
Health and Fitness Data
Activity Metrics: Information related to your fitness activities such as step count, sleep data, heart rate, exercise, HRV, RHR, blood oxygen saturation, and other wellness metrics.
Manually Entered Health Data: Any health-related information you choose to manually input, including diet, exercise, female health tracking, and personal wellness goals.
Personal and Device Information
Wallet Address: For blockchain-based transactions within the app.
Device Information: Including device type, operating system, IP address, unique device identifiers, and mobile network information.
Physiological Profile: Including birthday, gender identity, weight, and height.
Interaction Data: How you interact with the app, including feature usage, session times, and click paths.
Geolocation Data: Such as GPS, IP Address, and movement on certain exercise types if you give permission for us to collect this data.
Sensitive Information
Any other information you voluntarily provide that may be considered sensitive under privacy laws, including information related to physical or mental health.
2.How We Use Your Information
We collect and use the information for the following purposes:
Personalization: To offer customized wellness insights and recommendations based on your health and fitness data.
Transaction Processing: Using wallet addresses for secure transactions related to in-app purchases or blockchain activities.
Analytics and Improvements: To understand user behavior and improve app performance, features, and user experience.
Legal Compliance: To comply with laws, regulations, and requests from legal authorities.
Enable Third-party Integrations and Services: We process personal data you provide to us to enable third party integrations, services, features, and offerings. For example, with your permission, our Services may integrate with third party services like Google Health Connect and Apple HealthKit, or our partners. BNB Ring takes measures to help ensure third-party services protect your personal data, which means that BNB Ring only processes your data with respect to third-party integrations when you choose to integrate them with our Services, or when you provide the necessary consents. We process the data we receive from these third-parties according to applicable terms, such as the Google Health Connect Permissions policy and Google Limited Use requirements, as well as relevant third-party developer license agreements, as we become aware of those policies and agreements.
3.How We Share Your Information
We take your privacy seriously and only share data in the following circumstances:
Service Providers: We may share your data with third-party providers who assist with services such as data storage, cloud infrastructure, analytics, and customer support.
Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity.
Legal Obligations: We may share your data in response to a legal request or to comply with applicable laws.
User Consent: We will share your information if you explicitly consent to such sharing.
We do not sell your personal or sensitive information to third parties.
4.How You May Share Personal Data Through BNB Ring
Depending on your use of the Services, you may share Personal Data with:
Other users of the Services, such as through our BNB Ring sharing features, which allow you to share information and content with other users of the Service. Users are by default searchable by other users.
Third-party social media platforms or linked accounts, devices, or features, when you choose to connect your account on those services with BNB Ring or post content to social media, such as through the BNB Ring sharing feature.
The Public: When you make Personal Data visible to other users of the Services, including through the BNB Ring sharing features, it may become publicly available and can be collected, viewed, and used by anyone.
Managing Entities: If your use of the Services is on behalf of or managed by a managing entity, such as a coach, team, organizing body, or other affiliated entity, your account information and Personal Data may be shared with the managing entity subject to your consent. The managing entity will determine how the relevant information and content is shared.
Corporate Wellness Programs: If you use the Services in connection with an employer or organizational corporate wellness program, we may share your information with that organization subject to your consent. Typically, we will share only Aggregated Data with these organizations.
5.Data Security
We are committed to ensuring the security of your data. We implement appropriate technical and organizational measures, including:
Encryption: We encrypt sensitive data both in transit and at rest.
Access Control: We limit access to your personal data to authorized personnel who need it to perform their duties.
Regular Audits: We conduct regular audits of our data security practices to ensure compliance with industry standards.
Despite these measures, no security protocol is 100% secure. We encourage users to take steps to protect their own data, such as using strong passwords and enabling two-factor authentication where available.
6.Data Retention
We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy or as required by law. The specific retention period may vary depending on the type of data:
Health Data: Retained for as long as you use the app to allow for continuous wellness insights.
Personal Information: Retained until your account is deleted or upon your request.
Legal Requirements: Some data may be retained for longer periods as required by legal obligations.
7.User Control and Data Deletion
You have control over the data you provide and can exercise the following rights:
Access and Correction: You may request access to or correction of your personal data at any time.
Data Deletion: You can request the deletion of your account and data by contacting us at [support@bnbring.com]. We will process your request in accordance with applicable laws.
8.Children’s Privacy
Our app is not intended for use by children under the age of 13. We do not knowingly collect personal data from children. If you believe we have collected data from a child under the age of 13, please contact us at [support@bnbring.com] so we can take appropriate action.
9.International Data Transfers
We may transfer your data to servers located outside of your country of residence. When we do so, we ensure that appropriate safeguards are in place, in accordance with applicable data protection laws.
10.BNB Ring AI Coach & Third-Party AI Technology
BNB Ring AI Coach is a generative AI feature that is intended to help you understand and make progress toward your goals, decipher BNB Ring concepts, and provide educational guidance, integrating with the rest of the BNB Ring experience. BNB Ring AI Coach combines your unique, anonymized BNB Ring metrics with the science of BNB Ring to help optimize your health, fitness, and performance.
If you use BNB Ring AI Coach, please note that BNB Ring AI Coach leverages third-party AI technology provided by our LLM partner. This technology is trained on real-world data to generate intelligent and personalized responses in conversations with users. Responses are based on your requests and relevant information collected through your BNB Ring metrics.
We require our LLM partner to use your anonymized BNB Ring metrics only for the purpose of generating responses. Our LLM partner has a “Zero-Retention/Zero Training Policy” with respect to your BNB Ring metrics, meaning they will not store, retain, or use your metrics for any training purposes.
BNB Ring may retain the history of your conversations with BNB Ring AI Coach to ensure you continue to have access to previous conversations. You may delete your BNB Ring AI Coach chat data by contacting us.
11. Your Choices
Access, update, or delete: You may access, edit, or delete certain information through your account settings. You may request full deletion of your account and data by contacting us.
Privacy Settings: You can modify privacy settings under “Integrations & Privacy” in the app.
Geolocation Data: You can enable or disable location services on your device.
Wellness Data: You can stop the collection of wellness data by un-pairing your BNB Ring device.
BNB Ring AI Coach: You may enable, disable, or interact with this feature as you choose.
Do Not Track: The Services do not support “Do Not Track” requests at this time.
11.Other Sites and Services
The Services may contain links to third-party websites or online services. These are not endorsements, and we are not responsible for their actions. You should review their privacy notices to understand how they handle your data.
12.Contact Information
If you have any questions or concerns about this privacy policy or how we handle your personal information, please contact us at:
Email: [support@bnbring.com]
Mailing Address: Beatbit Inc., 1234 Wellness Drive, Miami, FL 33101
13.Changes to This Privacy Policy
We reserve the right to update or modify this policy at any time. If we make material changes, we will notify you via email or within the app prior to the change becoming effective. Please review this policy periodically for any updates.
Update Date: October 8, 2024
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
We are providing this supplemental privacy notice to consumers in California, pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”).
We do not sell Personal Data. As we explain in this Privacy Policy, we use Cookies and other tracking technologies to analyze website and application traffic and use, and to facilitate advertising. To limit use of Cookies and other tracking technologies, please reach out to us. You may also direct us to share your data, as described in the “How You May Share Personal Data Through BNB Ring” section of the Privacy Policy.
California Privacy Rights. If you are a California resident, you have the following rights:
Information: The Privacy Policy describes the types of Personal Data we collect in the “Information We Collect” section above. We describe the purposes for which we use and share this data in the “How We Use Your Information” section above and the “How We Share Your Information” section above.
Access: You can request a copy of the personal information that we maintain about you.
Deletion: You can ask to delete the personal information that we have collected from you.
Opt-out of sale of your Personal Data: We do not sell Personal Data. We offer instructions on how to limit online tracking, please contact us at[support@bnbring.com].
Please note that the CCPA limits these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request.
You are entitled to exercise the rights described above free from discrimination.
Exercising Your Rights. To exercise these rights, you can submit requests as follows:
To request access to or deletion of Personal Data collected via your use of the Services, please either email us at [support@bnbring.com].
To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional Personal Data to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.
Authorized agents: California residents can empower an “authorized agent” to submit requests on the resident’s behalf. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.
PRIVACY NOTICE FOR EUROPEAN RESIDENTS
If you are a resident of the European Economic Area, the United Kingdom, or Switzerland (collectively, “Europe”), you may have additional rights under the General Data Protection Regulation (the “GDPR”) or other European data protection legislation.
Controller and European Representatives. Beatbit, Inc. will be the controller of your Personal Data processed in connection with the Services.
Legal Bases for Processing. The “How We Use Your Information” section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others but will depend on the type of Personal Data and the specific context in which we process it. However, the legal bases we typically rely on for each category of processing activity are set out below.
Service delivery: Processing is necessary to perform our contract, or to take steps that you request prior to engaging our Services. Where we cannot process your Personal Data as required to operate the Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or Services you access and request.
Research and development: These activities constitute our legitimate interests.
Marketing and advertising: Processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business.
Compliance and protection: From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Consent: To the extent that Wellness Data that we collect is considered health data or another special category of Personal Data subject to the GDPR, we ask for your explicit consent to process this data. You can use your account settings and tools to withdraw your consent at any time, including by unpairing your BNB Ring Ring, stopping use of a feature, removing our access to a Third-Party service, or deleting your data or your account. In addition, in some cases, such as when you direct us to share it, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, you have the right to withdraw it any time in the manner indicated at the time you give consent or in as listed in our Services.
We may use your Personal Data for reasons not described in this Privacy Policy where permitted by law and where the reason is compatible with the purpose for which we collected it. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the applicable legal basis.
Retention. To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Data Subject Rights. You have certain rights with respect to your Personal Data, including:
Access. You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
Rectification. If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your account.
Erasure. You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of consent. If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability. You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection. You can contact us at[support@bnbring.com] to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of processing. You can ask us to restrict further processing of your Personal Data.
Right to file a complaint. You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or European Economic Area Member State.
For more information about these rights, or to submit a request, please email us. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Processing of Personal Data in the United States. To provide the Services, we will process your Personal Data in the United States, where BNB Ring is based. If such processing involves the transfer of Personal Data to the U.S. in a manner governed by European data protection law, the transfer will be performed pursuant to the applicable requirements of the law, such as standard contractual clauses, the individual’s consent, or other circumstances permitted by European data protection law.
Privacy Shield Certification. BNB Ring certified to the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU to the U.S. For more information about the Privacy Shield Program, and to view our certification, please visit www.privacyshield.gov.
Although BNB Ring no longer relies on the Privacy Shield Framework to facilitate cross-border data transfers, BNB Ring remains committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access, and (7) recourse, enforcement, and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield before it was invalidated. The Privacy Shield Principles require that we remain potentially liable if any Third-Party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Our compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Please contact us at[support@bnbring.com] with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States.
You can visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.
If you have any questions about this section or our data practices generally, please contact us at [support@bnbring.com] or using the contact information above.
PRIVACY NOTICE FOR QATAR RESIDENTS
Data Subject Rights
If you reside in Qatar, you have the following rights:
right to protection and lawful processing;
right to withdraw consent;
right to object to processing in certain circumstances;
right to erasure;
right to request correction;
right to be notified of processing;
right to be notified of inaccurate disclosure; and
right to access personal data.
If you reside in Qatar, you have the right to lodge a complaint with a supervisory authority, in addition to other rights set out in the Privacy Notice. The details of the supervisory authority are as follows:
National Cyber Governance and Assurance Affairs
Email: privacy@ncsa.gov.qa.
Basis of Lawful Processing
BNB Ring processes End User Personal Data on the following grounds:
Consent: When you have provided your consent or, in the case of sensitive personal information, when you have provided your explicit consent, to our collection of your information and we have obtained permission from the supervisory authority set out above;
Legitimate interests: When BNB Ring has a legitimate business or commercial reason for using your information, and your interests and your fundamental rights do not override those interests. We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice; and/or
Legal obligation:
When we need to comply with a legal or regulatory obligation.
Before collecting or using any special categories of data (referred to as sensitive personal information in the Privacy Notice), we will only use that information:
With your explicit consent; and
After having obtained the permission of the supervisory authority set out above.
BNB Ring may process your Personal Data on more than one ground depending on the reason or grounds for using your Personal Data. Please contact us at [support@bnbring.com] if you need details about the specific grounds we are relying on to process your Personal Data.
Personal Data of Children
If you are under the age of 18, please do not attempt to register for the Services or send any Personal Data about yourself to BNB Ring. If we learn that we have collected Personal Data from an unauthorized minor, we will promptly delete that information from our platform. If you believe that an unauthorized minor may have provided us Personal Data, please contact us at [support@bnbring.com].
Security Measures
BNB Ring ensures that adequate security measure comprising industry-standard encryption, regular cybersecurity assessments, continuity and disaster recovery testing, and robust access controls are implemented to protect the confidentiality, integrity, and availability of your personal information are implemented. Please contact us if you want more information on how we protect your personal information.
Transfer of Personal Data
In order to provide the Services, BNB Ring will transfer your Personal Data to the United States. BNB Ring will ensure that adequate safeguards are implemented if and when we need to transfer Personal Data outside of Qatar so that a similar degree of protection is afforded to it. Please contact us if you want more information on how we transfer and protect your Personal Data outside of Qatar.
PRIVACY NOTICE FOR BRAZIL RESIDENTS
If: (a) you are a Brazilian resident; (b) your Personal Information was collected in Brazil (e.g. you were located in Brazil at the moment that your Personal Information was collected); or (c) the data processing activities are being performed in Brazil, this section is applicable to you.
Controller. BNB Ring, Inc. will be the controller of your Personal Data processed in connection with the Services. Our contact information is as follows:
Legal Bases for Processing. The “How We Use Your Information” section above explains how we use your Personal Data. We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, performance of an agreement and our “legitimate interests” but will depend on the type of Personal Data and the specific context in which we process it. However, the legal bases we typically rely on for each category of processing activity are set out below.
Service delivery: Processing is necessary to perform our contract, or to take steps that you request prior to engaging our Services. Where we cannot process your Personal Data as required to operate the Services on the grounds of performance of an agreement, we process your personal information for this purpose based on our legitimate interest in providing you with the products or Services you access and request.
Research and development: Processing is based on our legitimate interests.
Marketing and advertising: Processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business.
Compliance and protection: From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.