Blue Spurs Consulting, Inc. (“Blue Spurs”, “we”, “our”, and “us”) respects your privacy. This Privacy Notice explains what personal data we collect about you, how it is used, with whom it is shared, and the choices you can make and rights you can exercise in relation to your personal data. This Privacy Notice applies to our Website located at www.bluespurs.com (“Website”) and all personal data we directly receive or collect from you in the course of doing business. We recommend that you carefully review this Privacy Notice before providing us with your personal data.
1. About Us
Blue Spurs provides managed services (the “Services”) to assist businesses in developing and utilizing AWS cloud services (“Clients”). Our Website provides visitors and prospective customers information about us and our Services.
For the purposes of applicable data protection laws, Blue Spurs is the controller of the personal data you provide directly to us. As the controller, we process personal data in accordance with this Privacy Notice. This Privacy Notice does not apply to personal data that our Clients collect or receive in utilizing our Services. In such cases, we are acting as a data processor. It is the Client who will remain responsible for the handling of personal data that the Client collects and for compliance with any applicable data protection and/or privacy laws. You should refer to the Client’s privacy notice for more information on the Client’s privacy practices.
2. Data We Collect
As used in this Privacy Notice, personal data is any information that personally identifies you or from which you could be identified either directly or indirectly. We collect personal data that you provide to us and well as certain data automatically from you.
2.1 Information that you provide:
You may provide us with personal data when you interact with our Website. For example, when you contact us or request information, you will be asked to provide your name, work email address, company name, and phone. We will need your name, company name, and work email to access publications and download information from our Website.
You may provide personal data through the use of our Services such as when you create an account to utilize our Services, work with our team, or request support. When you set up an account, you will be asked to provide certain basic personal data such as your name, work email address, username, password, company name, occupation, phone number, and work address.
2.2 Information we automatically collect:
Our Website contains social media features such as the Facebook and Twitter buttons that operate on our Website. These features may collect information such as your IP address and the pages you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on the Website. Your interactions with these features are governed by the privacy statement of the company providing the applicable feature.
We also use third party analytics tools, such as Google Analytics, to collect information regarding our Website and the performance of our Services. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in marketing and improving our Website and Services.
2.3 Information we collect from third-party sources:
We collect information from third-party sources including New Relic, Google, AdWords, and Salesforce regarding website usage and leads and sales information.
3. How We Use the Information We Collect about You
To the extent that we are a data controller, we use the information collected about you for the following purposes:
- to improve and optimize our Website;
- to respond to your inquiries and requests;
- to communicate with you through email, via the Website, phone calls, or otherwise;
- customer service and technical support, which may include responding to your requests, resolving issues, and/or troubleshooting problems;
- to diagnose problems and identify security risks, errors, technical problems, or malfunctions;
- research purposes with respect to our Website and Services;
- marketing, advertising, and sales efforts with respect to our Services;
- to provide you with information and publications about us and our Services;
- creating, processing, and managing your account; and
Information collected that is aggregated or statistical usage information that is not linked to any personal data, is not treated as personal data. To the extent that information is itself personal data, or is linked to personal data, we treat it accordingly.
4. Our Legal Basis for Processing Personal Data
If you are a visitor or customer located in the European Economic Area (“EEA“) or Switzerland, Blue Spurs is the data controller of your personal data. Blue Spurs' Data Protection Officer can be contacted via the information included in the Contact Us section below.
We will only collect and process personal data about you where we have a legal basis. Our legal basis for collecting and using the personal data described above will depend on the nature of the personal data and the specific context in which we collect it. However, we will normally collect personal information only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you.
Where we process personal data based on consent, we will ask for your explicit consent. You may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal. Where we rely on contract, we will ask that you agree to the processing of personal data that is necessary for entering into or the performance of your contract with us or the Client.
We may process your personal data for the purposes of our legitimate interests, provided that such processing does not outweigh your rights and freedoms. Where we rely on legitimate interests, you have the right to object. We process your personal data based on legitimate interests in order to:
- market our Services;
- protect you, us, or others from security threats;
- comply with laws that apply to us;
- enable or administer our business and Services; and
- improve our business, Services, and/or Client relationships.
5. How We Share Your Information
We share your personal data as follows:
5.1 Service Providers. We engage third-party service providers to assist in providing and optimizing our Website and Services. When we share personal data with third party service providers, we take steps to protect your personal data. We share personal data with our software and technology providers including AWS and Salesforce.
5.2 Law Enforcement, Government or Regulatory Bodies or Lawful Authorities. We may disclose personal data to comply with laws, regulations, or other legal obligations, to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce this Privacy Notice or agreement with third parties, or for crime-prevention purposes.
5.3 Corporate Transaction. We can also share your personal data as part of a sale, merger, change in control, or other corporate transaction, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your personal data, but only in the manner set out in this Privacy Notice unless you agree otherwise.
We do not sell your personal data to any third party.
6. Your Choices and Data Protection Rights
You can opt out of receiving marketing emails from us at any time. You can opt out of our marketing emails by clicking the “unsubscribe” link at the bottom of our marketing messages. Opt-out requests can also be made by via the below “Contact Us” section. Please note that it may take time to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make your request.
Please note that some Client communications are considered transactional and necessary for account management and you cannot opt out of these messages unless you cancel your Services.
By contacting us using the contact details provided under the below “Contact Us” section, for personal data that we have about you, you can:
- Access Your Data: You can ask us for a copy of your personal data.
- Correct or Update Your Personal Data. You can also ask us to change, update, or fix your personal data.
Additionally, if you are an EEA resident, for personal data that we have about you can also:
You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Object to, or Limit or Restrict, Use of Data. You can ask us to stop using all or some of your personal data (g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Take Your Data. You can ask us for a copy of your personal data provided in a machine-readable form.
You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the EEA and Switzerland are available on the European Commission website.)
If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond effectively to your request.
7. How We Keep Your Information Secure
Blue Spurs utilizes reasonable and appropriate technical and organizational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data based on the nature thereof.
8. International Data Transfers
Our servers and offices are located in Canada and the United States, so your personal data may be transferred to, stored, or processed in Canada or the United States. We will rely on legally-provided mechanisms to lawfully transfer personal data across borders. Canada or the United States may have data protection laws that are different to the laws of your country, and in some cases, may not be as protective.
In many cases, we will use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the EU.
You can find more information about Standard Contractual Clauses here on the European Commission website. These clauses are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of the data.
9. Third-party Websites and Social Media Features
This Privacy Notice does not apply to third-party websites or social media features that may be accessed through links that we provide for your convenience and information. Accessing those links will cause you to leave our Website and may result in the collection or sharing of personal data about you by a third party. We do not control, endorse, or make any representations about those third party websites or their privacy practices, which may differ from ours. We encourage you to review the privacy notice of any site you interact with before allowing the collection and use of your personal data.
We do not knowingly solicit or collect personal data through our Website from children under the age of 16 without verified parental or guardian consent. Please contact us as provided below in the Contact Us section if you believe we may have collected such information without parental or guardian consent.
11. Direct Marketing and Do Not Track Signals
We currently do not share personal data with, non-affiliated third parties for their direct marketing purposes without your permission.
California and Delaware laws require that we indicate whether we honour “Do Not Track” settings in your browser concerning targeted advertising. At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Thus, like many other websites, our Website is currently unable to respond to Do Not Track Signals. To find out more about “Do Not Track”, you may wish to visit http://www.allaboutdnt.com.
12. Changes to Our Privacy Notice
13. Contact Us
If you have any questions about our Privacy Notice, please contact us using the following details:
Phone: +1 (506) 455-4111
Blue Spurs Consulting, Inc.
10 Knowledge Park Drive, Suite 300
Fredericton, New Brunswick E3C 2M7
Last Update: This Privacy Notice was last updated on July 10, 2018.