Data treatment policy

Personal data we collect

Cco Systems collects data from you, through our interactions with you and through our products for a variety of purposes described below, including to operate effectively and provide you with the best experiences with our products.

We rely on a variety of legal reasons and permissions (sometimes called “legal bases”) to process data, including with your consent, a balancing of legitimate interests, necessity to enter into and perform contracts, and compliance with legal obligations, for a variety of purposes described below.

We also obtain data from third parties. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time and include:

• Data brokers from which we purchase demographic data to supplement the data we collect.
• Services that make user-generated content from their service available to others, such as local business reviews or public social media posts.
• Communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks.
• Service providers that help us determine your device’s location.
• Partners with which we offer co-branded services or engage in joint marketing activities.
• Developers who create experiences through or for Cco Systems products.
• Third parties that deliver experiences through Cco Systems products. Publicly-available sources, such as open public sector, academic, and commercial data sets and other data sources.

You have choices when it comes to the technology you use and the data you share. When you are asked to provide personal data, you can decline. Many of our products require some personal data to operate and provide you with a service. If you choose not to provide data required to operate and provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalisation that use the data will not work for you.

The data we collect depends on the context of your interactions with Cco Systems and the choices you make (including your privacy settings), the products and features you use, your location, and applicable law.

The data we collect can include the following:

Name and contact data. Your first and last names, email address, postal address, phone number and other similar contact data.

Credentials. Passwords, password hints, and similar security information used for authentication and account access.

Demographic data. Data about you, such as your age, gender, country/region and preferred language.

Payment data. Data to process payments, such as your payment instrument number (such as a credit card number) and the security code associated with your payment instrument.

Subscription and licensing data. Information about your subscriptions, licences and other entitlements.

Interactions. Data about your use of Cco Systems products. In some cases, such as search queries, this is data you provide in order to make use of the products. In other cases, such as error reports, this is data we generate. Other examples of interactions data include:

• Device and usage data. Data about your device and the product and features you use, including information about your hardware and software, how our products perform, as well as your settings. For example:
  • Payment and account history. Data about the items you purchase and activities associated with your account.
  • Browse history. Data about the webpages you visit.
  • Device, connectivity and configuration data. Data about your device, your device configuration and nearby networks. For example, data about the operating systems and other software installed on your device, including product keys. In addition, IP address, device identifiers (such as the IMEI number for phones), regional and language settings and information about WLAN access points near your device.
  • Error reports and performance data. Data about the performance of the products and any problems you experience, including error reports. Error reports (sometimes called “crash dumps”) can include details of the software or hardware related to an error, contents of files opened when an error occurred, and data about other software on your device.
  • Troubleshooting and help data. Data you provide when you contact Cco Systems for help, such as the products you use, and other details that help us provide support. For example, contact or authentication data, the content of your chats and other communications with Cco Systems, data about the condition of your device, and the products you use related to your help enquiry. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
  • Bot usage data. Interactions with third-party bots and skills available through Cco Systems products.
• Interests and favourites. Data about your interests and favourites, such as the sports teams you follow, the programming languages you prefer, the stocks you track or cities you add to track things like weather or traffic. In addition to those you explicitly provide, your interests and favourites can also be inferred or derived from other data we collect.
• Content consumption data. Information about media content (e.g., TV, video, music, audio, text books, apps, and games) you access through our products.
• Searches and commands. Search queries and commands when you use Bcc Systems products with search or related productivity functionality.
• Voice data. Your voice, data, sometimes referred to as “voice clips”, such as search queries, commands, or dictation you speak, which may include background sounds.
• Text, inking, and typing data. Text, inking, and typing data and related information. For example, when we collect inking data, we collect information about the placement of your inking instrument on your device.
• Images. Images and related information, such as picture metadata. For example, we collect the image you provide when you use Bing image-enabled service.
• Contacts and relationships. Data about your contacts and relationships if you use a product to share information with others, manage contacts, communicate with others, or improve your productivity.
• Social data. Information about your relationships and interactions between you, other people, and organisations, such as the types of engagement (e.g. likes, dislikes, events, etc) related to people and organisations.
• Location data. Data about your device''s location, which can be either precise or imprecise. For example, we collect location data using Global Navigation Satellite System (GNSS) (e.g., GPS) and data about nearby cell towers and Wifi hotspots. Location can also be inferred from a device's IP address or data in your account profile that indicates where it is located with less precision, such as at a city or postcode level.

Content. Content of your files and communications you input, upload, receive, create, and control. Other content we collect when providing products to you include:

• Communications, including audio, video, text (typed, inked, dictated, or otherwise), in a message, email, call, meeting request, or chat.
• Photos, images, songs, movies, software, and other media or documents you store, retrieve, or otherwise process with our cloud.

Video or recordings. Recordings of events and activities at Bcc Systems buildings, retail spaces, and other locations. If you enter Bcc Systems Store locations or other facilities, or attend to Bcc Systems event that is recorded, we may process your image and voice data.

Feedback and ratings. Information you provide to us and the content of messages you send to us, such as feedback, survey data, and product reviews you write.

Traffic data. Data generated through your use of Bcc Systems communications services. Traffic data indicates with whom you have communicated and when your communications occurred. We will process your traffic data only as required to provide, maintain, and improve our communications services and we do so with your consent.

Product-specific sections below describe data collection practices applicable to use of those products.

 

How we use personal data,

Bcc Systems use the data we collect to provide you rich, interactive experiences. In particular, we use data to:

• Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.
• Improve and develop our products.
• Personalise our products and make recommendations.
• Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you relevant offers.

We also use the data to operate our business, which includes analysing our performance, meeting our legal obligations, developing our workforce and doing research.

For these purposes, we combine data we collect from different contexts. However, we have built in technological and procedural safeguards designed to prevent certain data combinations where required by law.

Our processing of personal data for these purposes includes both automated and manual (human) methods of processing. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (AI), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do. To build, train, and improve the accuracy of our automated methods of processing (including AI), we manually review some of the predictions and inferences produced by the automated methods against the underlying data from which the predictions and inferences were made.

When we process personal data about you, we do so with your consent and/or as required to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests of Bcc Systems as described in this section and in the Reasons we share personal data section of this privacy statement. When we transfer personal data from the European Economic Area, we do so based on a variety of legal mechanisms, as described in the Where we store and process personal data section of this privacy statement.

More on the purposes of processing:

• Provide our products. We use data to operate our products and provide you with rich, interactive experiences. Additionally, as communications are a feature of various products, programmes and activities, we use data to contact you. For example, we may contact you by phone or email or other means to inform you when a subscription is ending or discuss your licensing account. We also communicate with you to secure our products, for example by letting you know when product updates are available.
• Product improvement. We use data to continually improve our products, including adding new features or capabilities.
• Personalisation. Many products include personalised features, such as recommendations that enhance your productivity and enjoyment. These features use automated processes to tailor your product experiences based on the data we have about you, such as inferences we make about you and your use of the product, activities, interests, and location. Many of our products provide controls to disable personalised features.
• Product activation. We use data—such as device and application type, location, and unique device, application, network, and subscription identifiers—to activate products that require activation.
• Product development. We use data to develop new products.
• Customer support. We use data to troubleshoot and diagnose product problems, repair customers’ devices, and provide other customer care and support services, including to help us provide, improve, and secure the quality of our products, services, and training, and to investigate security incidents. Call recording data may also be used to authenticate or identify you based on your voice to enable Bcc Systems to provide support services and investigate security incidents.
• Help secure and troubleshoot. We use data to help secure and troubleshoot our products. This includes using data to protect the security and safety of our products and customers, detecting malware and malicious activities, troubleshooting performance and compatibility issues to help customers get the most out of their experiences, and notifying customers of updates to our products. This may include using automated systems to detect security and safety issues.
• Safety. We use data to protect the safety of our products and our customers. Our security features and products can disrupt the operation of malicious software and notify users if malicious software is found on their devices.
• Updates. We use data we collect to develop product updates and security patches. For example, we may use information about your device's capabilities, such as available memory, to provide you a software update or security patch. Updates and patches are intended to maximise your experience with our products, help you protect the privacy and security of your data, provide new features, and evaluate whether your device is ready to process such updates.
• Promotional communications. We use data we collect to deliver promotional communications. You can sign up for email subscriptions and choose whether you wish to receive promotional communications from Bcc Systems by email, SMS, physical mail, and telephone. For information about managing your contact data, email subscriptions, and promotional communications, see the How to access and control your personal data section of this privacy statement.
• Relevant offers. Bcc System uses data to provide you with relevant and valuable information regarding our products. We analyse data from a variety of sources to predict the information that will be most interesting and relevant to you and deliver such information to you in a variety of ways. For example, we may predict your interest in gaming and communicate with you about new games you may like.
• Advertising. Bcc Systems does not use what you say in email, chat, video calls or voicemail, or your documents, photos or other personal files to target ads to you. We use data we collect through our interactions with you, through some of our products, and on third-party web properties, for advertising in our products and on third-party properties. We may use automated processes to help make advertising more relevant to you. For more information about how your data is used for advertising, see the Advertising section of this privacy statement.
• Prize promotions and events. We use your data to administer prize promotions and events available in our physical Bcc Systems Stores. For example, if you enter into a prize promotion, we may use your data to select a winner and provide the prize to you if you win. Or, if you register for a coding workshop, or gaming event, we will add your name to the list of expected attendees.
• Transacting commerce. We use data to carry out your transactions with us. For example, we process payment information to provide customers with product subscriptions and use contact information to deliver goods purchased from the Bcc Systems Store.
• Reporting and business operations. We use data to analyse our operations and perform business intelligence. This enables us to make informed decisions and report on the performance of our business.
• Protecting rights and property. We use data to detect and prevent fraud, resolve disputes, enforce agreements, and protect our property. For example, we use data to confirm the validity of software licences to reduce piracy. We may use automated processes to detect and prevent activities that violate our rights and the rights of others, such as fraud.
• Legal compliance. We process data to comply with law. For example, we use the age of our customers to assist us in meeting our obligations to protect children's privacy. We also process contact information and credentials to help customers exercise their data protection rights.
• Research. With appropriate technical and organisational measures to safeguard individuals’ rights and freedoms, we use data to conduct research, including for public interest and scientific purposes.

 

Reasons we share personal data

We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorised. For example, we share your content with third parties when you tell us to do so, such as when you send an email to a friend, share photos and documents or link accounts with another service. If you use Bcc Systems product provided by an organisation you are affiliated with, such as an employer or school, or use an email address provided by such organization to access Bcc Systems products, we share certain data, such as interaction data and diagnostic data to enable your organisation to manage the products. When you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.

In addition, we share personal data among Bcc System-controlled affiliates and subsidiaries. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we've hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.

Finally, we will retain, access, transfer, disclose, and preserve personal data, including your content, when we have a good faith belief that doing so is necessary to do any of the following:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
• Protect our customers, for example, to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone.
• Operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks.
• Protect the rights or property of Bcc Systems, including enforcing the terms governing the use of the services—however, if we receive information indicating that someone is using our services to traffic in stolen intellectual or physical property of Bcc Systems, we will not inspect a customer's private content ourselves, but we may refer the matter to law enforcement.

For more information about data we disclose in response to requests from law enforcement and other government agencies, please see our Law Enforcement Requests Report.

Please note that some of our products include links to or otherwise enable you to access products of third parties whose privacy practices differ from those of Bcc Systems. If you provide personal data to any of those products, your data is governed by their privacy policies.