Besitos Privacy Policy

Last Updated: 8.13.2025

Table of Contents

Besitos Corporation, LLC (“Besitos,” “we” or “us”) respects privacy and is committed to protecting personal information.  This Privacy Policy (the “Policy”) explains our practices for handling information we may collect and use about website visitors, prospective clients or partners, and others with whom we interact in making our website at besitoscorp.com available (the “Website”).  This Policy describes the types of personal information we may receive, how we may use and disclose the information, and certain rights and options individuals may have regarding their information.


By providing us with personal information or using the Website, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use the Website or provide us with your information.

Important Information About This Policy

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time, or to create additional policies, in order to accurately reflect changed circumstances or new legal requirements.  As a result, it is important that you read this Policy closely so that you are fully aware of how and why we are using your personal information.

To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates. We also ask that, where we have an ongoing relationship with you and any of the data you have provided becomes no longer accurate, you keep us informed of this so we can amend our records accordingly. 

Personal Information We Receive or Collect About You

For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual.  Our services are directed to business professionals and owners and, as a result, the personal information we collect is often the personal information of consumers acting in a commercial context.

A. Information You Provide


Personal Information we collect from you can be categorized as follows:

  • Contact information – first name, last name, email address, mailing address, telephone number.

  • Transactional information – details about your transactions with us, including method of payment, payments received, payment details, transaction history, and other information relating to any payments transmitted to us by you.
  • Marketing information – details regarding informational and promotional materials you may have requested or received from us, the properties or communities in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.

  • Communication information – copies of communications and inquiries you have submitted to us, including through email, calls, chatbots, and features available on our Website.

  • Device and usage information – details regarding how and when you use our website, including the device used to connect to our website, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to our website, and information about your interaction with our website.

We collect this information when you visit or navigate our website, fill in forms on through use of our Website, submit applications or inquiries to us, communicate with us (including by phone, email, or otherwise), visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.


Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.”  We may also collect information about you from third-party sources and information about you that is publicly available.

B. Automatically Collected Usage and Device Information

Like most website operators, we use various technologies to automatically collect information about visitors.  Those technologies include:

  • Cookies. Cookies are small text files that a website transfers to a visitor’s browser or device for record keeping purposes. We use cookies to personalize visitors’ experiences on our website, provide content that we believe may be of interest, track visitor trends and patterns, engage in marketing and advertising, and otherwise analyze our website traffic. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org. Please note that if cookies are disabled, you may not be able to enjoy certain features of our website. 

  • Log Files and Device Identifiers. We use log files to track actions occurring on the website and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers. This information is used for security purposes and to detect and prevent fraud. 

  • Pixels, tags, and web beacons. Our website may also use “pixels,” “tags,” or “web beacons.” When we refer to “pixels,” we are generally referring to all of these types of technologies. These technologies are small pieces of code that run when a page or email is loaded. They are used to monitor the behavior of the visitor or email recipient—such as what icons were clicked or whether links in an email were opened—and gather analytics. For example, when you open our homepage, a pixel may run and generate information based on the visit, and then this information is processed by us and our vendors. Pixels work in conjunction with cookies to let us know what portions of our website are of interest to you and to help us provide you with tailored information from our website. If you turn off cookies, the pixels, tags, and web beacons we use may still detect certain information about your interaction with our website and disregard any cookie-prohibitive markers or signals. Note, the vendors that supply us these pixels, tags, web beacons, or similar tracking technologies collect your personal information instantaneously and simultaneous to our collection of your information and they may use the information for their own or others’ purposes. 

  • Analytics. Our website may also use third-party analytics tools, such as Google Analytics. You can find more information about how data is collected and processed in connection with the Google Analytics service here. You can also read Google’s privacy policy here.


These technologies can be separated into the following categories: 

  • Essential Technologies: These technologies are necessary for the website to function and cannot be switched off in our systems. Examples include: Security technologies, technologies that allow pages to load correctly. 

     

  • Performance Technologies: These technologies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the Website. Examples include: Analytics technologies. 

  • Functional Technologies: These technologies are not strictly necessary for the website to function but help us improve your experience and understand how our site is used. Examples include: Technologies that read your browser settings and preferences.  
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  • Advertising Technologies: These technologies, such as pixels, support features like embedded videos or social media sharing. These technologies, including Meta, Google, and LinkedIn, may collect personal data and track your activity across other websites. We partner with advertising platforms such as Meta (including Facebook and Instagram), Google Ads, and LinkedIn Ads to deliver targeted advertising and measure the effectiveness of our campaigns. These platforms may collect information such as your IP address, device identifiers, browser activity, pages visited, and interactions with our advertisements, and may combine it with other information they have about you to provide you with more relevant ads on their networks and across the internet. For more information on how these platforms collect and use data, and how you can control your preferences, please visit their privacy policies and ad settings pages: Meta Privacy Policy https://www.facebook.com/privacy/policy, Google Privacy Policy https://policies.google.com/privacy, and LinkedIn Privacy Policy https://www.linkedin.com/legal/privacy-policy. 

The above technologies could be first-party technologies, meaning that they are set and controlled by us, or they could be third-party technologies that are controlled or managed by third-party vendors or partners. In particular, we use the following technologies supplied by third parties: 

  • Clarity: We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement. 

  • HubSpot: We use HubSpot for analytics, including understanding visitor behavior, traffic sources, and engagement with our website and content. In addition, HubSpot may be used to support our advertising efforts, such as creating matched audiences for targeted campaigns based on interactions with our website, forms, or marketing communications. HubSpot may collect information such as your IP address, browser type, device identifiers, and pages visited, and may combine this with other data to help us deliver more relevant marketing messages. For more information about how HubSpot collects and uses your data, please review the HubSpot Privacy Policy at: https://legal.hubspot.com/privacy-policy. 

  • RB2B: RB2B offers a tracking script that websites can implement to monitor user activity. It uses cookies and similar technologies to associate website visits or logins with personal information, such as email addresses. This data can then be used by the website or its service providers to send targeted communications and marketing messages. To opt out of certain processing of your personal information by RB2B, please visit https://www.rb2b.com/rb2b-gdpr-opt-out.

C. Information from Other Sources


We may obtain both personal and non-personal information about you from our vendors, affiliates, business partners, contractors, suppliers, and other third parties and add it to other information we have collected.  We, and the third parties we engage, may combine information we collect from you over time, and across our Website, with information obtained from other sources.  This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.


D. Social Media


If you interact with us on any social media platform (e.g., Meta, X, LinkedIn), depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy. In addition, where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts.  Social media platforms operate independently from us and we are not responsible for the personal information that you choose to submit or link on any social media platform.  We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices. 

How We Use Personal Information

We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:

  • Negotiating, entering into, and managing our relationship and agreements with you.
  • Process requests or inquiries regarding our software solutions or services.
  • Providing and optimizing your experience on our Website and ensuring that our content is presented to you in the most effective manner.
  • Communicating with you and communicating regarding our services, our agreements with you, and other issues.
  • Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.
  • Managing customer service issues, including issues relating to the performance of our services and user feedback.
  • Developing, updating, and improving our Website, user service, and user experience, and otherwise improving our knowledge and insights regarding customers and partners.
  • Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with our Website.
  • Enforcing our agreements with participants, partners, or vendors, complying with our legal or regulatory obligations, and defending or advancing legal claims.
  • Notifying you about changes to our Website or material changes to this Policy.
  • Providing you with surveys or otherwise soliciting feedback from you.
  • Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Personal Information” below.

Our Marketing Efforts

We may send you direct marketing communications from time to time including news, updates, offers, and other promotions relating to our services and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing from us, then you can always unsubscribe using the option provided in the footer of the communication you have received or by contacting us using the information below.

Disclosure of Personal Information

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or disclose it to third parties, to the extent permitted by applicable law.


In addition, we may disclose your personal information to the following types of third parties:

  • Service providers we use to facilitate our business operations and administration. For example, our service providers include (i) IT and system administration providers, (ii) data storage providers, (iii) vendors to facilitate payments and payment processing.

  • Marketing and advertising vendors that may assist with lead generation, hosting information relating to users and participants, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.
  • Analytics vendors in order to understand our website traffic and usage patterns, optimize our Website. Note, the technologies we use on our website to automatically collect information about you and your interaction with our website may be supplied by third-party vendors that collect your information instantaneously and simultaneous to our collection of your information. They may also use your information for their own or others’ purposes.
  • Affiliated entities who may use your information to provide you the details of their services or otherwise market to you.
  • Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
  • Our professional advisors, such as lawyers, accountants, and other similar advisors.
  • Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
  • Other parties for any purpose we disclose at the time you provide the information.

We further reserve the right to refer or disclose your information to law enforcement or regulatory authorities in the event that we believe you, other individuals, our partners or service providers, or anyone else is in danger, at risk of harm, in violation of applicable laws, or representing a safety concern.

Protection of Personal Information

We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification.  Please be aware that no data transmission over the Internet is 100% secure.  While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.

Your Choices About Personal Information

We respect your right to make choices about the ways we collect, use, and disclose your information.  We try to offer you meaningful choices regarding your personal information.  Some choices you have regarding personal information include the following.

  • Marketing Emails – As required by applicable laws, you can opt-out of receiving promotional emails from us by clicking the “opt out” link in any such promotional emails and following the instructions provided.
  • Tracking Technologies – Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same. Please note that if you disable or delete cookies, you may not be able to access or use certain features of our website. The National Advertising Initiative also makes resources available to assist consumers in opt-out of certain tailored online ads, which you can access here: https://optout.networkadvertising.org/?c=1.
  • Google Analytics – As discussed above, we use Google Analytics in connection with our Website.  If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can use.  You can find more information on how Google uses information it collects here.
    Declining to Provide Information – You can choose not to provide us with information we may request through our Website, but that may result in you being unable to use certain features of our Website, request information about our services, or initiate other transactions with us.
  • Do Not Track Mechanisms – Please note that our Website does not honor “Do Not Track” signals, and such signals will not impact the operation of our website.

In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.

Additional Information for California Residents

This Notice at Collection is provided pursuant to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”). It applies to California residents and provides details regarding the types of personal information that Besitos collects, and how we use that information, when an individual when accesses, uses, or interacts with our website or App.

Categories of personal information about consumers to be collected. * **


*No sensitive personal information about consumers will be collected.


**None of the information described in this Notice at Collection is “sold” or “shared” (as those terms are defined by the CCPA).

  • Identifiers and personal information, such as: unique personal identifier, online identifier, IP address; if you fill out a “Contact Us” form or similar, a real name, alias, postal address, email address, phone number.
  • Internet activity, such as unique personal identifier, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, including page views and clicking tendencies.

The business purposes for which the above categories of personal information are collected and used.

  • Providing and optimizing your experience on our website and ensuring that our content is presented to you in the most effective manner.
  • Communicating with you and responding to your inquiries.
  • Engaging in analytics regarding use of products and services.
  • For marketing to current or potential customers and partners.
  • Developing, updating, and improving our solutions, customer service, customer experience, and marketing efforts, and otherwise improving our knowledge and insights regarding customers.
  • To help maintain the safety, security, and integrity of our website.
  • Preventing and detecting fraud, hacking activities, security breaches, and other unlawful activities in connection with our solutions.

The criteria used by us to determine the period of time such personal information will be retained

We will retain the personal information we collect and use so long as we have a legitimate business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is the longer.

To learn more about our online and offline practices in connection with the collection, processing, and disclosure of personal information relating to California residents, continue to read this section.


Information We Collect and Disclose

As defined by the CCPA, “personal information” includes any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information certain regulated information or public information.


In the past 12 months, Besitos has collected the following categories of personal information from consumers and disclosed such information to the following categories of third parties for the business or commercial purposes described below.

Categories of PI Collected

Examples

Categories of Third Parties to Whom Disclosed 

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. 

  • IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers, and IT consultants
  • Online analytics and marketing/advertising service providers
  • Financial institutions and payment processors
  • Professional advisors (accountants, lawyers, and auditors)
  • Other users of our services whom you direct us to provide the information

Commercial information 

Records of services purchased, obtained, or considered by you or your organization, or other purchase histories, customer services inquiries, requests, and communications. 

  • IT and cloud/hosting service providers, such as our email providers, business application providers, hosting providers, managed services providers, and IT consultants
  • Marketing/advertising service providers
  • Financial institutions and payment processors
  • Professional advisors (accountants, lawyers, and auditors)

Internet or other similar network activity 

Browsing history, search history, information on a consumer’s interaction with our website, including forms on our website. 

  • IT and cloud/hosting service providers
  • Online analytics and marketing/advertising service providers

Personal information types listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) 

A name, signature, address, telephone number, or employment information. 
Some personal information included in this category may overlap with other categories. 

  • IT and cloud/hosting service providers, such as our email providers, business application providers, hosting providers, managed services providers, and IT consultants
  • Online analytics and marketing/advertising service providers
  • Professional advisors (accountants, lawyers, and auditors)
  • Other users of our services whom you direct us to provide the information

Professional or employment-related information

Employer, position

  • IT and cloud/hosting service providers, such as our email providers, business application providers, hosting providers, managed services providers, and IT consultants
  • Marketing/advertising service providers
  • Financial institutions and payment processors
  • Professional advisors (accountants, lawyers, and auditors)
  • Other users of our services whom you direct us to provide the information

Sensory data 

Voicemail or similar audio recordings. 

  • IT and cloud/hosting service providers, such as our email providers, business application providers, hosting providers, and telephone communication providers

Categories of PI Collected

Identifiers

Examples

We will retain the personal information we collect and use so long as we have a legitimate business need to do so, or as required by law (e.g., for tax, legal, accounting, or other purposes), whichever is the longer.

Categories of Third Parties to Whom Disclosed 

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. 

  • IT and cloud/hosting service providers, such as our email providers, business application providers, managed services providers, and IT consultants
  • Online analytics and marketing/advertising service providers
  • Financial institutions and payment processors
  • Professional advisors (accountants, lawyers, and auditors)
  • Other users of our services whom you direct us to provide the information

Categories of PI Collected

Commercial information 

Examples

Records of services purchased, obtained, or considered by you or your organization, or other purchase histories, customer services inquiries, requests, and communications. 

Categories of Third Parties to Whom Disclosed 

  • IT and cloud/hosting service providers, such as our email providers, business application providers, hosting providers, managed services providers, and IT consultants
  • Marketing/advertising service providers
  • Financial institutions and payment processors
  • Professional advisors (accountants, lawyers, and auditors)

Categories of PI Collected

Internet or other similar network activity 

Examples

Browsing history, search history, information on a consumer’s interaction with our website, including forms on our website. 

Categories of Third Parties to Whom Disclosed 

  • IT and cloud/hosting service providers
  • Online analytics and marketing/advertising service providers

Categories of PI Collected

Personal information types listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) 

Examples

A name, signature, address, telephone number, or employment information. 
Some personal information included in this category may overlap with other categories. 

Categories of Third Parties to Whom Disclosed 

  • IT and cloud/hosting service providers, such as our email providers, business application providers, hosting providers, managed services providers, and IT consultants
  • Online analytics and marketing/advertising service providers
  • Professional advisors (accountants, lawyers, and auditors)
  • Other users of our services whom you direct us to provide the information

Categories of PI Collected

Professional or employment-related information

Examples

Employer, position

  • IT and cloud/hosting service providers, such as our email providers, business application providers, hosting providers, managed services providers, and IT consultants
  • Marketing/advertising service providers
  • Financial institutions and payment processors
  • Professional advisors (accountants, lawyers, and auditors)
  • Other users of our services whom you direct us to provide the information

Categories of PI Collected

Sensory data 

Examples

Voicemail or similar audio recordings. 

  • IT and cloud/hosting service providers, such as our email providers, business application providers, hosting providers, and telephone communication providers

From time to time, Besitos may be required to disclose your information to governmental authorities for the purpose of complying with applicable laws and regulations or in response to legal process. We may also disclose your personal information to third parties in connection with the sale of our business or assets, or any merger or similar corporate matter, when your personal information is part of the assets involved in such transaction.

Finally, we may “aggregate” or “deidentify” information from you pursuant to the CCPA, in which event the information is no longer “personal information.”


Applicable Retention Periods

For each category of personal information identified above, we will retain your personal information only for as long as necessary to fulfill your requests or the purposes for which it was obtained, as set forth in this Notice. The criteria used to determine our retention periods include (i) to fulfill the purpose for which the information was collected, (ii) for as long as we have an ongoing relationship with you, and (iii) as required by a legal obligation to which we are subject.

Categories of Sources of Personal Information


Besitos collects these categories of personal information from the following categories of sources:

  • Direct collection: We collect information directly from you when you choose to provide it to us by filling out forms on our website, engaging in transactions with us, signing up to receive promotional or information communications from us, communicating with us about our solutions, or otherwise directly providing the information to us.
  • Indirect and technology-based collection: We also collect certain information from you automatically when you visit, use, or navigate our Website. Besitos collects certain identifiers (such as IP addresses) and internet and similar network activity (such as website usage data) from you indirectly using cookie, pixels, and passive tracking technologies.
  • Collection via social media: We may collect personal information about social media users, including basic user profile information (such as username), user-generated content (such as posts, comments, pages, profiles, or feeds) and associated metadata (such as time and location of a post or comment); contact details (such as name, email address, telephone number, if made public by the user); and additional individual information published by the user (such as employer, profession, age, location, education information, habits, etc.). The type and scope of personal data obtained from social media platforms depends on the type of APIs and permissions set out by the respective platforms and the administrative permissions granted by customers, where applicable.
  • Third-party collection: We will obtain information from our marketing and advertising vendors.

Business or Commercial Purposes for Collecting and Disclosing Personal Information
We collect and disclose the personal information described above for the following business or commercial purposes (as well as any other purposes as set forth in our Privacy Policy).

  • Providing and optimizing your experience on our Website and ensuring that our content is presented to you in the most effective manner.
  • Providing you with our products and services, as well as any reasonable customer support services.
  • Fulfilling transactions with you or your organization, processing your payments, and managing the transaction process.
  • Communicating with you and responding to your inquiries about our services, including to provide you with promotional and informational communications regarding our services, informing you about new solutions, updating you about changes to our website, and investigating any concerns you have about our solutions or your transactions.
  • Developing, updating, and improving our services, customer service, customer experience, and marketing efforts, and otherwise improving our knowledge and insights regarding customers.
  • Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the website or purchase and use of our solutions.
  • Enforcing our agreements with our organizational partners or service recipients and complying with our legal or regulatory obligations.
  • Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

Sensitive Personal Information


Besitos does not use or disclose “sensitive personal information” (as defined by the CCPA) for the purposes of inferring characteristics about California consumers. Accordingly, Besitos treats any such information as “personal information” consistent with applicable provisions of the CCPA.


Sale or Sharing of Personal Information


In the past 12 months, Besitos has not “sold” or “shared” any categories of personal information, as those terms are defined by the CCPA. Besitos does not have actual knowledge that it sells or shares the personal information of consumers under 16 years of age.


Your Rights Under the CCPA


Subject to exceptions, the CCPA provides California residents with the rights discussed below.  For convenience, and as required by the CCPA, we explain how you can exercise those rights, to the extent they are applicable.

1. Right to Know. You have the right to request that we provide you certain information about our collection and use of your personal information during the past twelve (12) months (or longer, as permitted by the CCPA). Specifically, you may request that we disclose (in whole or part):


  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • The business and commercial purposes for collecting (or selling or sharing, if applicable) your personal information;
  • The categories of third parties to whom we disclose (or sell or share, if applicable) your personal information;
  • The specific pieces of personal information we collected about you;
  • If we disclosed your personal information for a business purpose, the categories of personal information received by each category of third party; and
  • If applicable, the categories of personal information that we sold, and for each category, the categories of third parties whom such information was sold.


As noted above, you have the right to request that we provide copies of the specific pieces of personal information we collected about you. If a verifiable consumer request is made, and subject to any exceptions or limitations under the CCPA, we will take steps to deliver the personal information to you either by mail or electronically. If we provide the information to you electronically, it will be in a portable and readily useable format, to the extent technically feasible. Consistent with the CCPA and our interest in the security of your personal information, we will describe but may not provide copies of certain personal information we may receive from you (e.g., driver’s license number, other government-issued identification number, financial account number, health or medical identification number, account password, or security questions or answers) in response to a CCPA request, to the extent any of those items are in our possession.

2. Right to Request Deletion. You have the right to request that we delete personal information we collected from you, subject to any exceptions or limitations under the CCPA.

3. Right to Correct Inaccurate Information. If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Consumers in California also have the right to opt-out of (a) the sale of personal information, or (b) the sharing of their personal information for the purposes of cross-context behavioral advertising (as defined in the CCPA). California consumers also have the right to limit the use or disclosure of sensitive personal information by the business if such information is used or disclosed for certain purposes, as required by the CCPA. Because Besitos does not engage in any of the foregoing activities, these rights are not available. Exercising Your Rights To exercise the rights described above, you—or someone authorized to act on your behalf—must submit a verifiable consumer request to us by sending an e-mail to: privacy@besitoscorp.com with the subject line: “CCPA Request” or calling us at 888-322-6094. Your request must include your name, email address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. If you are an agent submitting a request on behalf of a consumer, we may request that you submit a signed permission from the consumer authorizing you to make the request. In order to protect the privacy and data security of consumers, the verifiable consumer request must:
  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such consumer; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

As indicated above, please be aware that the CCPA provides certain limitations and exceptions to the foregoing rights, which may result in us denying or limiting our response to your request.


You may only make a verifiable consumer request to know twice within a 12-month period. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We may also request that you provide additional information if needed to verify your identity or authority to make the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or the consumer on whose behalf you are making the request.


Response Timing and Format


The CCPA requires us to respond to a verifiable consumer request within forty-five (45) days of its receipt; however, we may extend that period by an additional 45 days. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response via e-mail. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request, provided that you may request disclosure beyond the 12-month period as permitted by the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests to know specific pieces of information collected about you, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another. We will not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request.


Our Commitment Not to Discriminate


Consistent with the CCPA, we will not discriminate against you for exercising any of your CCPA rights by:

  • Denying you goods or services.
  • Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Providing you a different level or quality of goods or services.
  • Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to this Notice


We reserve the right to amend this Notice at our discretion and at any time. If there are changes to this Notice, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes. Please check this page periodically for updates.


Data Disclosures for Direct Marketing Purposes


California Civil Code § 1798.83 (California’s Shine the Light Act) further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from providing your personal information to certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.

Additional Information for EEA, UK, and Swiss Residents

The European Union’s General Data Protection Regulation and the United Kingdom’s and Switzerland’s versions of the same (collectively, referred to as the “GDPR”) afford certain rights to individuals in the European Economic Area or Switzerland, Gibraltar, United Kingdom and similar, as applicable (collectively, referred to as “Europe”).  If you are in Europe, you have the following rights.  Note, however, that not all rights apply in all circumstances. 

  • Right of access: subject to certain exceptions, you have the right of access to your personal information that we hold. If you are requesting access to your data in order to protect the rights of others, we may require you to validate your identity before we can release that information to you.
  • Right to rectify your personal information: if you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e., corrected).
  • Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances. This right is not absolute, and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.
  • Right to restriction of processing: in some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.
  • Right to object to processing: you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.
  • Right to data portability: you have the right to receive, move, copy, or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.

With regard to the personal information discussed in this Policy, we are typically the “data controller” for such information under the GDPR.  As a result, if you wish to exercise one of the rights discussed above, you may do so by submitting a written request to the email address below with the subject line, “GDPR Request.”  This is normally free, unless this process is unduly difficult or is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond.  Once we have received your request, we will review it and contact you within thirty (30) days of receipt of your request, will notify you of any delay in processing your request and, in any event, will respond to the request within three (3) months.  Please note that we may need to request specific information from you to help us confirm your identity.  If you are located in Europe and have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in your jurisdiction of residence.   

We will process different types of information under different lawful bases under the GDPR depending on the nature of the information and your relationship with us. The following table describes how we plan to use your personal information and our lawful basis for doing so.  We may process your personal information on more than one basis depending on the specific purpose for which we have collected or are otherwise using your information. If the lawful basis is your consent, you have the right to withdraw your consent. Please note, we do not engage in automated decision-making. 

To enter into and subsequently to manage our business relationship with you or your company, including:

  • Providing you with the products and services you have requested or purchased
  • Responding to inquiries and providing customer support and service 
  • Managing and processing transactions for our services 
  • Notifying you about changes to our services, business terms, or this Policy 
  • Communicating with you and responding to your inquiries regarding our services, agreements with you or your company, and other issues
  • Contact Information  
  • Transactional Information
  • Communication Information
  • Necessary for our legitimate interests (to manage our business relationships and administer our operations including through the keeping of appropriate records) 
  • Necessary for performance of a contract
  • Necessary to comply with legal obligations

To administer and protect our business and services including: 

  • Defending and advancing legal claims  
  • Enforcing our rights under any agreements 
  • Ensuring effective security for our website 
  • Conducting website and platform maintenance   
  • Identifying and addressing security risks and unlawful activity
  • Contact Information  
  • Transactional Information
  • Communication Information
  • Device and Usage Information
  •  
  • Necessary for our legitimate interests (running our business, facilitating administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) 
  • Necessary to comply with legal obligations
  • Necessary for performance of a contract 

To make decisions about how best to deliver relevant content and advertisements to you, and otherwise market to you, and to better understand the effectiveness of our marketing efforts 

  • Contact Information  
  • Transactional Information
  • Marketing Information
  • Communication Information
  • Device and Usage Information
  • Necessary for our legitimate interests (better understanding website and platform functionality and how website users navigate and interact with the site) 
  • With your consent

To advance and promote our business interests including contacting you regarding products, services, or promotions that may be of interest to you or your company, conducting surveys or soliciting feedback on our services, and updating, developing, and improving our products/services, customer service, and marketing efforts  

  • Contact Information  
  • Transactional Information
  • Marketing Information
  • Communication Information
  • Device and Usage Information
  • Necessary for our legitimate interests (to enhance our services, improve our marketing strategies and develop our business)
  • With your consent

If we transfer personal information from the EEA, Switzerland, or UK to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal data protection consistent with the GDPR’s requirements. For example, if the recipient country has not received an Adequacy Decision from the European Commission (such as the United States), we will rely on Standard Contractual Clauses (SCC) that have been approved by the European Commission as the lawful mechanisms for such transfers. Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors that contain SCCs and define data protection standards to be employed by each (sub)processor. 

Data Retention

We retain personal information for as long as necessary to fulfil the purposes we collected it, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements.  We also consider any specific limitation periods under applicable law.

Data Location

You understand and agree that information about you may be stored or processed by information technology systems located in the United States or jurisdictions that may have laws that differ from the laws of your country of residence or the jurisdiction in which you reside.

Links to Third-Party Websites

Our website may contain links to third-party websites, including the websites of vendors we use to process information on our behalf.  Such websites have separate privacy policies that you should review.  We do not control these third-party websites and are not responsible for the content of linked websites or those companies’ data-handling practices.

Children’s Privacy

Our Website is intended for a general audience and is not directed at, or intended for use by, children under the age of 13 years.  Accordingly, we do not knowingly collect personal information from children under age 13.  Should we discover that a child under the appropriate age provided his or her personal information, we will use that information only to respond to that child and inform him or her that we must have parental consent before receiving such information.

Changes to this Policy

Please note that we may change this Policy from time to time.  If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of our Website after any changes is deemed to be acceptance of those changes.  Accordingly, we encourage you to check the Policy periodically for updates.

How to Contact Us

For questions or more information about our privacy practices, please contact us by using the contact information provided below:

Besitos Corporation, LLC