Privacy Policy

Last Updated: February 2, 2024

INTRODUCTION

Bennie Health, Inc. (“Bennie”, “we”, “us”) has created this privacy policy (“Privacy Policy”) in order to set out how we collect, use, share, and disclose personal information through our website located at https://www.bennie.com/ (the “Website”) and our mobile app (the “App”) that is offered as part of the Bennie Platform and Bennie Brokerage. The Bennie Platform allows a company’s human resources team to manage its employee population and employee benefits program, and access reports on employee and dependent data that include benefits enrollments, account balances and usage for various employment benefits. The Bennie Platform also allows a company’s employees to access their benefits enrollments, account balances and usage for various employment benefits, and facilitates communication between a company’s employees and the Bennie service team via phone or encrypted in-app messaging. The Bennie Brokerage service allows Bennie to offer benefits consulting and advisory services to companies and their human resources teams. This Privacy Policy applies to the Website, the App, and all of the products, services, and websites, including any related software, domains, subdomains, content, and versions and upgrades thereto, offered by Bennie or our related, affiliated and/or subsidiary companies (collectively the “Services”).

The privacy of our customers and their employees is important to us. By visiting using the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy. As further explained below, Bennie may change this Privacy Policy from time to time by posting changes at https://www.bennie.com/privacy-policy and may send notification emails regarding such changes. Your continued use of the Services following the posting of such changes will be deemed your acceptance of those changes.

The information available through the Services is not intended or implied to be a substitute for professional medical advice, diagnosis or treatment. All content, including text, graphics, images and information, contained on or available through the Services are for general information purposes only. Bennie makes no representation and assumes no responsibility for the accuracy of information contained on or available through the Services, and such information is subject to change without notice. You are encouraged to confirm any information obtained from or through the Services with other sources, and review all information regarding any medical condition or treatment with your physician. NEVER DISREGARD PROFESSIONAL MEDICAL ADVICE OR DELAY SEEKING MEDICAL TREATMENT BECAUSE OF SOMETHING YOU HAVE READ ON OR ACCESSED THROUGH THE SERVICES. IF YOU EXPERIENCE A MEDICAL EMERGENCY OR IMMEDIATE NEED FOR CARE, DIAL 911 OR CONTACT YOUR LOCAL EMERGENCY SERVICES.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals and information which can be used to identify an individual (“Personal Information”). As discussed further below, Personal Information does not include “aggregate” information which we de-identify and aggregate from information (including Personal Information) you provide to us. Personal Information may be collected about our customers, prospective customers, visitors to the Website, and end users of the Services. In some instances, you may choose not to provide us with certain information, but by doing so, you may not be able to take advantage of many of the features and functionality of our Services. However, in order to provide the Services to you, certain Personal Information is required.

You understand and agree that Bennie and its authorized business partners, affiliates, subsidiaries or agents may collect, use, share, and disclose information provided by you, on and through the Services. You represent and warrant that you have permission to share any information you elect to provide to Bennie, you consent to such information being shared with third parties, including, if applicable, healthcare providers, insurance companies, and other third parties supporting the delivery of your employee benefits program, and that such information is accurate, current, non-misleading, and consistent and relevant for our provision of the Services or for the purpose for which you are providing information.

This Privacy Policy does not apply to practices of any third-party we do not own or control. Third parties who provide products, services or functions on our behalf may include business analytics companies, customer service vendors, communications service vendors, marketing vendors, and security vendors. We may also authorize third-party vendors to collect information on our behalf, including as necessary to operate features of the Services or provide online advertising tailored to your interests. Third-party vendors have access to and may collect Personal Information only as needed to perform their functions, may only use Personal Information consistent with this Privacy Policy and other appropriate confidentiality and security measures, and are not permitted to share or use the information for any other purpose. Please note that our partners may contact you as necessary to obtain additional information about you, facilitate any use of the Services, or respond to a request you submit. Bennie is not a party to any agreement between you and third-party provider and does not control the third party’s privacy and data security policies.

Bennie does not recommend, endorse or make any representation about the efficacy, appropriateness or suitability of any specific tests, products, procedures, treatments, services, opinions, health care providers, health insurers, health plans, or other information that may be contained on or available through the Services. Bennie IS NOT RESPONSIBLE NOR LIABLE FOR ANY ADVICE, COURSE OF TREATMENT, DIAGNOSIS OR ANY OTHER INFORMATION, SERVICES OR PRODUCTS THAT YOU OBTAIN THROUGH THE SERVICES.

COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA

User Account Information: In order to use the Services, users will be required to have a valid Bennie account to log in to the Website (an “Account”). In connection with its provision of the Services and as further detailed below, Bennie collects your name, email address, birth date, gender, zip code, your business phone number and business address (“Account Information”). Bennie will also have access to information about you and your use of the Services such as information provided by your employer, insurance information and any other information that you may upload.

Additionally, Bennie collects the following Personal Information:

We may periodically obtain information about you from affiliated entities, partners and other independent third-party sources and will add it to our database of information, including any information that you provide to third parties that are associated or whose products and/or services are integrated with the Services. For one example, we may receive information from a healthcare clearing house system or benefit administration system to update our database.

Generally, Bennie uses the Account Information (including Personal Information) to deliver the Services to you, to improve the delivery of our Services and related products and services, to conduct our business, to develop analytics and create de-identified aggregated data that allow us to improve our Services and related products and services, or to correspond with you. Specifically, Bennie uses Personal Information to:

• Authenticate access to the Account and provide access to the Services;
• Provide, operate, maintain and improve the Services;
• Send technical notices, updates, security alerts and support and administrative messages;
• Provide and deliver the Services and features you request, process and complete transactions, and send you related information, including confirmations and invoices;
• Respond to comments, questions, and requests and provide customer service and support;
• Communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about us and our select partner;
• Investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
• Personalize and improve the Services, and provide content, features, and/or advertisements that match your interests and preferences or otherwise customize your experience on the Services;
• Monitor and analyze trends, usage, and activities in connection with the Services;
• Link or combine with other information we receive from third parties to help understand your needs and provide you with better service;
• Obtain pricing and proposals from insurers, partners, and other employee benefit vendors for review and selection by your employer;
• Enable you to communicate, collaborate, and share files with users you designate; and
• Carry out other legitimate business interests about which we will notify you about and seek your consent.

Bennie may publish, share, distribute, disclose, or use aggregated and de-identified information, including but not limited to, employer, employee and benefit plan data, in order to provide benchmarking and/or other analytics reports to employers, insurers, health care providers, and other third parties and in a manner that does not allow third parties to de-aggregate the data and identify it as originating from you. Bennie may use Personal Information for its management and administration. We may share de-identified data with third parties as permitted or required by law.

Some of the Personal Information received by Bennie in connection with the Services may be provided by employers in their capacity as a self-insured health plan entity that is subject to laws and regulations, such as rules issued under the Health Insurance Portability and Accountability Act of 1996 as amended by the Health Information Technology for Economic and Clinical Health Act of 2009, including implementing regulations (“HIPAA”), that govern the use and disclosure of certain individually identifiable Personal Information processed by health care providers, health insurers, business associates and other covered entities as defined in HIPAA (“Protected Health Information”). When we receive Protected Health Information, we may do so as a “Business Associate” of the employer under an agreement that, among other things, prohibits us from using or disclosing the Protected Health Information in ways that are not permissible by the employer itself, and requires us to implement certain measures to safeguard the confidentiality, integrity, and availability of the Protected Health Information. When we act as a Business Associate, we may be subject to certain laws and regulations, including HIPAA, that govern our use and disclosure of Protected Health Information and that may be more restrictive than otherwise provided in this Privacy Policy. For more information about how we comply with HIPAA, please contact askbennie@bennie.com.

Prospective Customers: We collect names, email addresses, other personal information, and business contact information about individuals who we consider to be prospective customers and business partners (“Prospects”).

We may use third-party service providers in order to collect, store and process Personal Information about Prospects. We use these third-party service providers to identify Prospects and locate contact information to contact Prospects about our products and services.

Website Visitors and App Users: As you use the Services, we collect information about the device and browser you use, your network connection, your IP address, and information about the cookies installed on your device. This information is logged to help diagnose technical problems for analytics and for quality control purposes. We also collect Personal Information submitted by any user of our Services through messaging features we make available and use such information for the purpose of responding to your requests.

Cookies: A cookie is a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. We may assign a different cookie to each device that accesses our Website. Bennie requires authentication and authorization to in order to process Account access. As such, we may use cookies throughout the Services to authenticate users. We use the following types of cookies:

• Essential Cookies. Essential cookies are necessary for providing you with services and features that you requested. For example, these cookies allow you to log into and stay logged into secure areas of the Services, save language preferences, and more. These cookies are required to make the Services available to you, so they cannot be disabled.
• Functional Cookies. Functional cookies are utilized to record your choices and settings, maintain your preferences over time, and recognize you when you return to our Services. These cookies help us personalize our content for you, greet you by name, and remember your preferences. Some examples include your ability to comment on a blog, facilitate web chat services, update user preferences, and more.
• Performance/Analytical Cookies. Performance/Analytical cookies allow us to understand how visitors (like you) use our Services. These cookies accomplish this by collecting information about the number of visitors to the Services, what pages visitors view the most, and how long visitors view specific pages. These cookies also help us measure and manage the performance of our advertising campaigns in order to help us improve the campaigns and the Services’ content.

By using our Services, you indicate your consent for Bennie and our affiliates to send cookies to your computer or mobile device in order to uniquely identify your device and improve the quality of our services; you may turn off cookies in your browser though, in doing so, some or all of our Service features may not work.

We may use cookies to recognize devices and provide a personalized experience through the Services. In particular, Bennie may use session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Bennie to process your online transactions and requests. Session cookies help us make sure you are who you say you are after you’ve logged in and are required in order to use the Services.

Marketing and Other Communications: We may use your Personal Information to contact you to tell you about products or services we believe may be of interest to you. For instance, when you enroll and provide your email address, or if your employer provides us with your email address, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. If you provide your telephone number, you acknowledge and agree that we may contact you, including but not limited to for promotional, informational, and other purposes, and push notifications (if applicable).

You are not required to consent to receive promotional messages or phone calls as a condition of using the Service. You can also control the marketing emails and push notifications you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future communications, you may contact us using the contact information at the end of this Policy. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests. We will not use your Protected Health Information for marketing purposes, unless you provide express consent to do so.

Compliance with Law: We may use Personal Information to comply with applicable laws, lawful requests and legal process, and to defend us against legal claims or disputes, as further described below.

ONLINE TRACKING

We and our third-party service providers may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Services and use that information to send targeted advertisements. At this time, the Services do not support Do-Not-Track signals.

Log Files: Like many internet and mobile services, we may automatically gather certain information about our Services traffic and store it in log files. This information includes mobile device identifiers, browser type, IP address, mobile or internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Services, to track users’ movements around the Services, and to gather demographic information about our user base.

We also store in our log files information identifying users who have accessed data that we store about employers and their employees, and any changes they make to such data. We use this information to comply with legal obligations relating to such data and to keep a record of such changes. We may also use it to improve our Services.

We may link this automatically collected data to Personal Information. Device identifiers may be tied to Personal Information to troubleshoot access issues.

Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Website and enhance your experience when you use the Website. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. We may also use other third-party tracking services that use log files, cookies, and possibly other techniques to track non-Personal Information about visitors to the Services in the aggregate. These services capture usage and volume statistics as well as geographical location data to compile usage reports and maps for optimization and troubleshooting purposes.

We do not assume liability for the policies or procedures of third parties. While we make diligent efforts to maintain the accuracy of the information provided above and update it as necessary, it is provided as a courtesy and may not always reflect the most current or precise details. We recommend that you reach out to the relevant third parties directly for inquiries pertaining to their privacy and data security policies and practices.

• Google
• Google Analytics
• LinkedIn
• WordPress

DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

We do not sell or rent your Personal Information to anyone.

Service Providers and Business Partners: We may from time to time employ third parties to perform tasks on our behalf and we may need to disclose Account Information and other Personal Information to them to provide certain services, including third party providers of voluntary insurance policies, products, and services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. These third parties may also be required to comply with the restrictions set forth under HIPAA. We currently engage third party companies and individuals employed by us to facilitate our Services, including the provision of maintenance services, database management, Web analytics and general improvement of the Services, and businesses who engage our Services (to the extent provided for above).

Business Transfers: If our business (or substantially all of our assets or stock) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

With Your Consent: If we need to use or disclose any Personal Information including Protected Health Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.

As Required by Law: We may disclose Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other end users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to: (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce our contracts or user agreement, including investigation of potential violations hereof; and (iii) detect, prevent, or otherwise address fraud, security or technical issues. We may disclose Personal Information if we believe it is necessary to investigate potential violations of our Terms of Service, or to enforce those Terms of Service. The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.

RETENTION

We will keep Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. Unless otherwise set forth in the applicable Terms of Service or a separate agreement with you governing the applicable Services, if you cease using such Services, we may retain or destroy, at our discretion, all Personal Information and non-personally identifiable information we collect through your use of such Services. All retained Personal Information will remain subject to the terms of this Privacy Policy.

ACCESS, CORRECTION AND ACCURACY OF PROTECTED HEALTH INFORMATION

You have the right to access the Protected Health Information we hold about you in order to verify the Protected Health Information we have collected about you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Protected Health Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will strive to keep Protected Health Information accurate and up to date, and we will provide mechanisms to update, correct, delete or add to Protected Health Information as appropriate. As appropriate, this amended Protected Health Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Protected Health Information about you enables us to give you the best possible service. In the event Protected Health Information relates to an employer’s employee, and we are providing services as a Business Associate, the terms of the Business Associate Agreement will dictate the manner in which we update, correct, or remove Protected Health Information. In the event there is a conflict between this Privacy Policy and the Business Associate Agreement, the Business Associate Agreement will control.

ADDITIONAL PRIVACY RIGHTS AND CHOICES FOR PERSONAL INFORMATION

Our databases are currently located in the United States. Bennie makes no claim that its Services are appropriate or lawful for use or access outside the United States. If you access the Services from outside the United States, you are consenting to the transfer of your personal information from your location to the United States. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and access to the Services. By sending us your information, you further consent to its storage within the United States.

We offer additional choices with respect to our handling of Personal Information that’s not Protected Health Information. Depending on your location and the nature of your interactions with our Service, you may request:

• Information about how we have collected and used Personal Information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the Personal Information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
• Correction of Personal Information that is inaccurate or out of date.
• Deletion of Personal Information that we no longer need to provide the Services or for other lawful purposes.
• Opt out of sharing of your Personal Information or use of your Personal Information for interest-based advertising. To exercise this right, you can click the “Your Privacy Choices” link on the footer of our Website.

To make a request, please email us or write to us as provided in the “Additional Information” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “Additional Information” section below.

MINORS

While Bennie may collect information regarding children under the age of 13 in the event they are the dependent of an employee enrolling in their employer’s benefits program, Bennie does not knowingly solicit or collect data from children nor knowingly market products or services to anyone under the age of 13. If you are under the age of 13 or the lowest age permitted by applicable law, you are explicitly not authorized to use the Services. If you become aware that your child has provided us with Personal Information without your consent, please contact us at Askbennie@Bennie.com. If we become aware that a child under 13 has provided us with Personal Information, we will take reasonable steps to remove such information from our systems and terminate the applicable account.

INFORMATION SECURITY

You use the Services at your own risk. We have implemented commercially reasonable technical, administrative, and organizational measures designed to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to us may not be secure, though we employ end-to-end encryption for any emails originating from Bennie. Therefore, you should take special care in deciding what information you send to us via the Services or email. Please keep this in mind when disclosing any Personal Information, including Protected Health Information, to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained in the Services, or third party websites.

LINKS TO OTHER WEBSITES

The Services may contain links to other websites and services operated by third parties, including insurance providers listed the Services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. These links are not an endorsement of or representation that we are affiliated with any third party. Please contact the Third Party Sites directly for information on their privacy practices and policies.

TERMS OF SERVICE

Please also visit our applicable Terms of Service, which govern the use of our Services.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date at the top of this page. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website, Website or Services after such changes have been first posted.

CALIFORNIA RESIDENT PRIVACY RIGHTS

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us or write to us at the addresses below.

EUROPEAN UNION, UNITED KINGDOM, AND SWISS DATA SUBJECT RIGHTS

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Switzerland, Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) or the Swiss Federal Act on Data Projection, as applicable, with respect to your Personal Data. The following discusses these rights.

For this section, the GDPR definition of “Personal Data” and “processing” are used. Generally, “Personal Data” means information that can be used to individually identify a person, and “processing” relates to actions that can be performed in connection with collecting, using, storing, and disclosing such data. Bennie is the controller of your Personal Data processed in connection with the Services.

If a conflict exists between this section and any other provision of this Privacy Policy, the more protective policy or portion shall govern to resolve such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at askbennie@bennie.com.

We may also process Personal Data of our customers’ end users in connection with our provision of the Services to our customers. In this case, we are the processor of Personal Data. If you have any questions regarding Personal Data when Bennie is the data processor, please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect. The “Collection and Use of Personal Information and Other Data” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds. The “Collection and Use of Personal Information and Other Data” section above explains how we use your Personal Data. We will only process your Personal Data as explained in this Privacy Policy and if we have a lawful basis for doing so. The lawful bases include receiving your consent, having a contractual necessity, and furthering our legitimate interests or the legitimate interest of others. The following sections describe these in greater detail.

Consent

We process Personal Data based on the consent you expressly grant to us at the time we collect the data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Contractual Necessity

We may process the Personal Data as a matter of “contractual necessity”. This means that we need to process the data to perform under our agreement with you and enable us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services.

Legitimate Interest

We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties providing products or services in connection with the Services:

• Profile or Contact Data
• Identifiers
• Commercial Data
• Online Identifiers
• Device/IP Data
• Web Analytics
• Geolocation Data
• Other Identifying Information that You Choose to Provide

We may also de-identify or anonymize Personal Data to further our legitimate interests (as described in more detail above in the “Collection and Use of Personal Information and Other Data” section).

Examples of these legitimate interests include (as described in more detail above in the “Collection and Use of Personal Information and Other Data” section):

• Providing, customizing, and improving the Services.
• Marketing the Services.
• Corresponding with you.
• Meeting legal requirements and enforcing legal terms.
• Completing corporate transactions.

Other Processing Grounds

Occasionally, we may also need to process Personal Data to comply with legal obligations, to protect the vital interests of you or other data subjects, or to carry out a task necessary for the public’s interest.

Sharing Personal Data. The “Disclosure of Personal Informaiton to Third Parties” section above details how we share your Personal Data with third parties.

EU and UK Data Subject Rights

EU and UK data subjects have certain rights with respect to Personal Data. This is further set forth below. For more information about these rights or to submit a request, please email us at askbennie@bennie.com. Please note that in some circumstances, Bennie may be unable to fully comply with your request, including if the request is frivolous, extremely impractical, jeopardizes other’s rights, or not required by law. In those circumstances, we will still notify you of such a decision. Generally, we may also need you to provide us additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. Your rights include:

• Access: You can request information related to the Personal Data we store about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we store about you is incorrect or incomplete, you can request we supplement or correct such Personal Data.
• Erasure: You can request we erase part or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based with your consent (as indicated at the time of collection of such data), you have the right to withdraw consent at any time. However, please note that if you change or withdraw consent, you may have to then provide express consent on a case-by-case basis if use or disclosure is necessary to enable you to use the Services.
• Portability: You can request for a copy of your Personal Data in a machine-readable format. You can also request we transmit the Personal Data to another controller to the extent such transmission is technically feasible.
• Objection: You can contact to object to our further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes, by contacting us as described above.
• Restriction of Processing: You can request Bennie to restrict further processing your Personal Data.
• Right to File Complaint: You have the right to submit a complaint about Bennie’s practices with respect to your Personal Data to the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data. The “Additional Privacy Rights and Choices for Personal Information” section above details how and where we transfer your data. Most significantly, our databases are currently located in the United States, and you are consenting to Bennie transferring your Personal Data to the United States.

ADDITIONAL INFORMATION

If you have questions regarding our Privacy Policy, its implementation, and/or our general practices, please contact us: AskBennie@Bennie.com.