Button Up Management Privacy Policy

I. Overview

Button Up Management, its subsidiaries and affiliates (hereinafter referred to as “We”, “Us”, and “Our” (and other similar terms)) understand that your privacy is important to you and are committed to respecting your privacy and protecting your personal data. We may process your personal data in the capacity of data controllers. This Privacy Policy (“Policy”) explains how We protect, collect, store, use, process and disclose Personal Data (defined below) from individuals (“you”) and what choices you can make with respect to your Personal Data.

This Policy explains Button Up Management practices when We process your “Personal Data,” By submitting your personal data to Button Up Management, you acknowledge that you have read and understood this Policy and agree to the use of your Personal Data as set out here. “Personal Data” which is information that relates to an identified or identifiable individual. To “process” or “processing” means any use of personal data including, transferring, collecting, recording, storing, using, analyzing, combining, disclosing or deleting it.

This Policy may be updated periodically. If we plan to make any material changes to the way we handle Personal Data as described here, we will notify you by posting an updated version of this privacy statement on Button Up Management website.

II. General Disclosure

Button Up Management’ data centers are hosted in the United States. Please note that by providing us with your personal information it may be stored or processed in a country different from your country of residence that may not have privacy laws that are as strong or comprehensive as the privacy laws in your own country. If you do not wish to allow the collection, processing, and storage of your personal information within a country different from your country of residence, you should not engage with Button Up Management or use the Website. You should also opt out of the collection of cookies by following the guidelines in our section titled “How To Control Cookies” in our Cookie Policy. Depending on your country of residence, applicable privacy laws may provide you with a right to additional disclosures as well as special data subject rights with regard to your personal information. This Statement applies to Button Up Management and all of its subsidiaries, and affiliates globally. We are not responsible for the privacy practices of third parties, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “in cooperation with” relationships). We do not share information we gather with other websites, entities, or individuals unless such sharing is disclosed to you in advance through this Statement. To ensure privacy protection, always review the privacy policies of the websites you visit.

III. What Information Do We Collect?

Button Up Management may collect and process different types of Personal Data in the course of operating our business, engaging personnel and providing our services. Such personal data may include, without limitation:

Personal Data You Provide

We collect some Personal Data when you use Our Website or when you communicate directly with us, including when you:

Visit our website;

Participate in a promotion or survey;

Use any of our other services

Apply for a job

Through these interactions, you may provide Us with the following categories of Personal Data:

Identifiers such as your first and last name, email address, postal address, phone number, username and password, social media handle, date of birth, or other similar identifiers.

Protected characteristics such as your gender, age, race, or other protected classifications under applicable law.

Financial, medical, or health information such as medical condition information, bank or credit card numbers or other financial information.

Audio, electronic, visual, thermal, olfactory, or similar information such as photographs of you, biometric identifiers, or voice recordings from you.

Professional information such as information about your employer, salary, job history, job interests, or job title.

Education information such as your education history, degrees or certifications obtained.

Communications. When you participate in polls or surveys, register for an event or contact us, we may maintain a record of that communication including any Personal Information you provide in the communication.

You may choose not to provide Personal Information or withdraw any consent you have provided to our processing of your information at any time, although it may affect our ability to provide you with relevant information or services.

Personal Data Received from Third Parties

We also collect some Personal Data from other sources, such as our affiliates, subsidiaries, or other third parties, directly or through technology such as cookies.

Personal Information we receive from Third Parties may include the following categories of Personal Information:

Identifiers such as your first and last name, email address, postal address, phone number, username and password, social media handle, or other similar identifiers.

Protected characteristics such as your gender, age, race, or other protected classifications under applicable law.

Professional information such as information about your employer, salary, job history, job interests, or job title.

Educational information such as your education history, degrees or certifications obtained.

In order to offer you a more consistent and personalized experience in your interactions with Button Up Management, information collected from one source may be combined with information Button Up Management obtains through other sources. This may include information that allows us to identify you across multiple devices through which you access our website. We may also supplement the information we collect with information obtained from other parties, including our business partners and other third parties.

Other Data Collected Automatically by Our Website

When you visit our website, we may utilize cookies or similar technologies to automatically receive the following categories of information:

Identifiers such as your computer’s internet protocol (IP) address, your operating system and browser type, your general geographic location or other persistent identifiers.

Internet or other electronic network activity information such as the pages you visit on our website, links and advertisements you click, search terms you enter, the Uniform Resource Locator (URL) address of any referring website length of time spent on a webpage.

This information is also used to operate, maintain, and manage our website. For example, we may calculate the average number of site visitors who visit a particular webpage on our website.

IV. Third Party Links On Our Website

The Website may contain links to other third-party websites for your convenience. For example, you may find advertising or other content on our Website that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control these third-party websites and are not responsible for the privacy policies and practices of other third parties. By visiting third party websites, your Personal Information may be collected by that third party and will be subject to the third party’s privacy policies. Once you leave the Button Up Management Website or are redirected to a third-party website, application, or other online service, we encourage you to read the privacy policy applicable to that third party to understand how that third party collects and processes your data.

V. What Is Our Purpose And Legal Basis For Processing Your Personal Information?

PURPOSE LEGAL BASIS

Improve Customer ServiceProcessing is necessary for the purpose of legitimate interest pursued by Button Up Management. The information you provide helps us deliver the services you have requested and to respond to your customer service requests.

Process Payments

Processing is necessary for the performance of a contract between you and Button Up Management. We may use the information you provide to process your payments. We do not share this information with outside parties except to the extent necessary to provide the service or complete payment.

Communicate With You

Processing is necessary for the purpose of legitimate interest pursued by Button Up Management, if you have opted-in, we may use your Personal Information to communicate with you about Button Up Management services and offerings, including company news, updates, related offerings or service information. To update your preferences or to opt-out of receiving certain communications, please see How to Access and Control Your Personal Information below.

Recruitment and Hiring

Processing is necessary for the purpose of legitimate interest pursued by Button Up Management. We may collect applicant’s personal information for recruitment purposes to ensure that Button Up Management recruits the right candidate for a specific or future role. For this purpose, Button Up Management provides additional privacy notices prior to collection of personal information.

Protect Security of our Website and to Prevent Fraud

Processing is necessary for the purpose of legitimate interest pursued by Button Up Management. We may use the information you provide to protect the security and integrity of our Site, business(es) and services, and to prevent fraud and other prohibited or illegal activity.

Enforce our Conditional SalesProcessing is necessary for the purpose of legitimate interest pursued by Button Up Management. We may use the information you provide to enforce our conditions of sale, website terms and/or separate contracts (if applicable) with you.

For Other Disclosure Purposes

Processing is necessary for the purpose of legitimate interest pursued by Button Up Management. We may use your Personal Information for other reasons, as disclosed to you at the point of collection.

We may aggregate or de-identify any information collected about you through your interactions with Button Up Management or the Website, and we may use that aggregated or de-identified information for any purpose.

VI. When Do We Disclose The Information We Collect?

We may disclose Personal Data to affiliates, business partners and advertisers to perform services on our behalf, to complete the transaction of a service you have authorized, or to provide information you have requested.

We may disclose your Personal Information with certain parties in order to achieve our own business purposes. These receiving parties and occasions may include:

Service providers and business partners. We engage service providers and business partners to assist us with operating and providing you access to the Website and other Button Up Management services. These service providers or business partners may perform advertising services, process secure payments, fulfill orders, optimize services, provide technical services, serve online behavioural advertising, send newsletters and surveys, support email and messaging services, administer polls and surveys, and analyze information. Some of our service providers or business partners may engage their own service providers or business partners to further assist us. In these instances, the receiving party cannot retain, use, or disclose Personal Information for any purpose other than for the specific purpose of performing that business purpose on our behalf. These companies will only use your Personal Information in the ways described in this Privacy Policy.

Where required by law. We may share your Personal Data with law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.

In the context of a transaction. We may share your Personal Data with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business.

The following categories of your Personal Data (as defined above) may be shared with these parties:

Identifiers;

Protected characteristics;

Commercial information;

Geolocation data;

Internet or other electronic network activity information;

Financial, medical, or health information;

Audio, electronic, visual, thermal, olfactory, or similar information;

Professional information;

Education information;

Communications.

VII. Cookies & Other Similar Technologies

Our website may also include web beacons and cookies from third party service providers. Cookies are small text files sent from a website and stored on your browser while you visit a website. Cookies track how you use a website and enable the website to remember your preferences and settings and help us analyse how our website is performing. You may choose not to receive certain cookies by making changes to your cookie preferences through the options available in your web browser; however, please note this may affect the availability of certain features of our website. For more information, please review our full Cookie Policy.

VIII. How Do We Keep Your Information Secure?

We use certain physical, administrative and electronic safeguards to protect the security, confidentiality and integrity of Personal Information. While no method of data transmission or storage is 100% secure, and we cannot guarantee that our network or systems will never be compromised, we take reasonable measures to protect your Personal Information against loss, destruction, alteration, or unauthorised access or disclosure.

If you are a resident of the European Economic Area (EEA), and your personal data is transferred outside of the EEA, we will:

Process it in a territory which the European Commission has determined provides an adequate level of protection for personal information

Implement appropriate safeguards to protect your personal information, including transferring it in accordance with applicable transfer mechanisms, including the European Commission’s Standard Contractual Clauses.Entering into intra-group data processing agreements with non-EU recipients that require them to provide the same level of protection, or relying on other legally-approved transfer mechanisms.

IX. How Long Do We Keep Personal Information

We retain Personal Information for as long as it is necessary to provide the services you have requested and for other legal compliance or essential business purposes such enforcing our contracts, maintaining the security of our services, business(es) and website, enforcing our legal rights, or dispute resolution.

X. Children’s Online Privacy

Button Up Management does not intend to collect or maintain personal data of individuals under 18 years of age. IF YOU ARE UNDER 18 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS OUR WEBSITE(S) OR OTHERWISE PROVIDE ANY INFORMATION TO Button Up Management WITHOUT THE KNOWLEDGE AND CONSENT OF YOUR PARENT/GUARDIAN. If we learn that personal data of an individual under 18 years old has been collected without verifiable parental consent, then we will take the appropriate steps to delete such information. Please delete all Button Up Management-related cookies and restrict the further collection of cookies using the methods outlined in the section “How to Disable Cookies” in our Cookie Policy.

XI. How To Access And Control Your Personal Information?

You have choices about how to manage your Personal Information and what types of communications you receive from us. Please note that we may have a legal obligation to preserve certain data and that we may need to request information from you in order to confirm your identity. This is to ensure that we can locate relevant data and that your Personal Information is not disclosed to a person who does not have a right to receive it. Except where not permissible under local law, you may be required to pay a fee for the administrative cost of providing you with a copy of your data.

Marketing Communications: You may choose to opt-out of receiving certain email communications from us by using the unsubscribe link email communication you receive from us, visiting the applicable email preference centre, or by contacting us directly.

Access to Your Personal Information: If you have provided Personal Information directly to us, you may contact us by email at support@buttonupmanagement.com or at the telephone number or postal mail address at the end of this Privacy Policy to request access to, correct, change or delete your Personal Information.

EU Site Visitors and Customers:

European Privacy Rights: If you reside in the European Economic Area, you may have the right to exercise certain privacy rights available to you under applicable laws. We will process your request in accordance with applicable data protection laws. We may need to retain certain information for record-keeping purposes or to complete transactions that you began prior to requesting any deletion.

Right not to provide consent or to withdraw consent. We may seek to rely on your consent in order to process certain personal data. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.

Right of access and/or portability. You may have the right to access the personal data that we hold about you and, in some limited circumstances, have that data provided to you so that you can provide or “port” that data to another provider.Right of erasure. In certain circumstances, you may have the right to the erasure of personal data that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected).

Right to object to processing. You may have the right to request that Button Up Management stop processing your personal data and/or to stop sending you marketing communications.

Right to rectification. You may have the right to require us to correct any inaccurate or incomplete personal information.

Right to restrict processing. You may have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).

Right to lodge a complaint to your local Data Protection Authority. If you are an EEA resident, you have the right to complain to a data protection authority about our collection and use of your personal data.

Please note that we may have legal or other obligations to preserve certain data which could prevent us from deleting certain data.

California Site Visitors and Customers: In accordance with the requirements of the California Consumer Privacy Act, you may have certain rights in relation to your Personal Information.

Your California Privacy Rights: If you are a resident of the State of California, this Privacy Statement is supplemented by our California Privacy Rights Statement which explains your California privacy rights and how you can exercise these rights.

How to Exercise Your Rights

If you have any questions about this Privacy Policy, please contact us at support@buttonupmanagement.com

Please identify yourself and specify your request. If you have an existing account with Button Up Management, we will use your account information to verify your identity. If not, we will ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.

We use commercially reasonable efforts to delete your personal data as required but retain records necessary to comply with a governmental authority or applicable federal, state, or local law. Where legally permitted, we may decline to process requests, including requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others.Privacy Principles

The privacy principles in this Privacy Policy have been developed based on the introduction of the EU General Data Protection Regulation and the Philippines Data Privacy Act including additional policies such as the Cookie Policy have been developed to reflect changes in EU.

Notice

Where Button Up Management collects personal information directly from you, it will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Button Up Management, or as soon as practicable thereafter, and in any event before Button Up Management uses or discloses the information for a purpose other than that for which it was originally collected.

Choice

Button Up Management will offer You the opportunity to choose (opt in/opt-out) whether your Personal Information is (a) to be disclosed to a non-processor third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by You.

For Sensitive Personal Information, Button Up Management will give you the opportunity to affirmatively and explicitly consent (0pt-in) to the disclosure of the information to a non- processor third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. Button Up Management will provide you with reasonable mechanisms to exercise their choices. You can modify your information at any time by request, or ask that your information be deleted. You can also request and select to have your information used in a limited way.

Data Integrity and Purpose Limitation

Button Up Management will use personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by You. Button Up Management will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

Recourse, Enforcement and Liability

Button Up Management will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Policy, and to assess potential liability in cases of onward transfer to third parties. Any employee that Button Up Management determines is in violation of this Privacy Policy will be subject to disciplinary action up to and including termination of employment. Button Up Management commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Button Up Management at:

Button Up Management Privacy Office

1255 Jefferson Street #204

Hoboken, NJ 07030

Accountability for Onward Transfer

Button Up Management will obtain assurances from third parties that they will safeguard Personal Information consistently with this Policy. Examples of appropriate assurances that may be provided by third parties include: a contract obligating the third party to provide at least the same level of protection as is required by Regulation (EU) 2016/679 the General Data Protection Regulation “GDPR”, or being subject to another European Commission adequacy finding (e.g., companies located in Canada). Where Button Up Management have knowledge that a Processor is using or disclosing Personal Information in a manner contrary to this Policy, Button Up Management will take reasonable steps to prevent or stop the use or disclosure.

XII. Fulfillment Policy

Refunds

Service Agreements between Button Up and its clients will define a billing dispute process. If it is determined that an overpayment has been made to Button Up, Button Up will either refund the overpayment to the account or card the payment was made from, or deduct the overpayment amount.

Delivery

Delivery of Button Up services to clients will differ in method depending on the services rendered. In most cases, Button Up will supply client with a CRM, customized to the client's needs, and will perform the contracted services by employing agents to make calls, perform outreach, or otherwise manage client's contacts within this CRM. Depending on services rendered, Button Up may also integrate with client's existing tools and platforms or continuously import client data into the CRM for ease of use and visibility.

Returns

All services provided by Button Up are intangible and thus no material returns are applicable to Button Ups services. If there is a billing dispute, it will be handled via the steps outlined in this policy above.

Cancellations

Button Up services are unique to the clients they are provided for, and as such, the process of service cancellation will vary from client to client and will be defined in the service agreement between Button Up and its client. In most cases Button Up requires a 30 day written cancellation notice in order to terminate an active service agreement or otherwise cancel services.

XIII. How To Contact Us

Email: support@buttonupmanagement.com

Telephone: (646) 921-7900

Postal Mail:

Attention: Button Up Management Privacy Office,Button Up Management, LLC

1255 Jefferson Street #204

Hoboken, NJ 07030

XIV. Changes To This Privacy PolicyFrom time to time it may become necessary to update or change our Privacy Policy consistent with changes in data protection laws and Button Up Management’ privacy program. Button Up Management has the discretion to update this Privacy Policy at any time. When we do, we will revise the updated date at the top of this page.

If we change Button Up Management Privacy Policy, we will post those changes on this page. If we make any changes to this Privacy Policy that materially change how we treat your Personal Information, we will endeavour to provide you with reasonable notice of such changes, such as via prominent notice in the Button Up Management website or to your email address of record, and where required by law, we will obtain your consent or give you the opportunity to opt out of such changes. By continuing to use the Button Up Management website and Button Up Management services without consenting to the changes or opting out, it will be deemed that you have consented to such changes by your conduct.

We encourage you to periodically check here for the most current version of Button Up Management Privacy Policy to stay informed about how we are helping to protect the Personal Information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.