I. Our Collection, Use, and Sharing of Your Information

A. Information that you submit to us.

In general, BBB  National Programs uses information you affirmatively submit to us for the purpose for which it is submitted, such as to reply to your email, respond to your inquiry, handle your complaint, process billing transactions, register your participation in an event, respond to requests related to program participation, review applications to be a BBB National Programs arbitrator, and communicate with you when appropriate.

BBB National Programs relies on information collected from our users to develop new services and conduct analyses to enhance current content and services. Information collected from you may be used in aggregate form to review usage and operations of our site and address issues with our site. We may also use personal information we collect for operational notices, in program record-keeping, and to conduct research on industry marketplace practices. We may publish aggregate data to report trends and statistics, but the aggregate data will not include personal information.

Specifically, we may collect and process personal data you submit to us under the following circumstances:

1. While you use our public website.

You can affirmatively submit to BBB National Programs certain information as you make use of our online services, which we use for purposes of delivering our website and services to you and for analytics. Such information may include the contents of a search query or other text that you type in our web forms. We do not share this information with third parties except agents we may contract with to deliver our services and for analytics.

2. As part of a consumer complaint regarding a business, advertisement, or online service.

If you submit a complaint to one of our programs through an online form or other method, we may collect your name and contact information as well as any other information you voluntarily provide. Please do not include sensitive information as part of your complaint. We may use information you provide to us in a complaint for purposes of contacting you about your complaint and resolving your complaint. We also use complaint information in aggregated form for purposes of analyzing and reporting complaint trends.

If you submit a complaint to BBB AUTO LINE, you may be asked to provide other information necessary to verify and process your complaint, including information about your vehicle. See the BBB AUTO LINE section of this privacy policy for full details.

If you submit a complaint to a program in the Global Privacy Division  (including Data Privacy Framework ("DPF") Services), you may be asked for further information including that needed to verify your identity for purposes of resolving the complaint. Individuals in the European Economic Area, United Kingdom, and Switzerland, please see the Special Notice for European Individuals below.

If you submit a complaint to the Digital Advertising Accountability Program , you do so through the complaint portal hosted by our third-party vendor Freshworks, Inc. In order for us to process and respond to your complaint, the Freshworks complaint portal collects your contact information and may infer additional information about your device, such as operating system and web-browser version. Any use by Freshworks of collected or inferred data of visitors to its website beyond those purposes directly contracted by BBB National Programs is covered by the Freshworks privacy policy.

Under certain circumstances, we may share the contents of your complaint with any business mentioned in the complaint. At our discretion, we may also share complaint information with another appropriate organization for purposes of facilitating the resolution of your complaint. We may publish reports that include aggregate complaint statistics and, if required, anonymized complaint details. We will not otherwise share complaint information with non-agent third parties.

3. When registering for or accessing a user account with the Online Archive.

Individuals who wish to access National Advertising Division (“NAD”), Children’s Advertising Review Unit (“CARU”), Digital Advertising Accountability Program (DAAP) and Electronic Retailing Self-Regulatory Program (“ERSP”) case reports as well as National Advertising Review Board (“NARB”) panel reports, should subscribe to the Online Archive. When you register as an Online Archive subscriber, we collect the name, business name, and job title for each licensed user of your account as well as contact information including email address, phone number, and billing address. We use this information to provide you with the Online Archive service and to contact you in relation to this service. We may also contact you with more information about our programs, events, and services. We do not share your contact information with third parties, except agents who help us provide our service, as identified below.

4. When registering for or sponsoring an event or conference.

When you register for or sponsor a BBB National Programs-hosted conference or other event, we collect your name, business name, title, email address, and phone number. We use this information to keep you informed about the event, to send you information about our programs, services, and future events as well as, if relevant, membership or sponsorship opportunities. You also have the option to provide us with your Twitter handle to facilitate ongoing discussion and, as applicable, the state in which you practice law for purposes of applying for CLE credits.

The registration process for our conferences is handled by a third-party agent, Cvent, which is authorized to use your personal information solely for purpose of providing the services that BBB National Programs has contracted it to provide and for any purposes described in Cvent’s privacy policy.

We may share your name, business name, and title with other conference attendees, speakers, and/or conference sponsors. We do not otherwise share conference registration information with non-agent third parties.

5. When applying to BBB National Programs in an individual capacity.

When you apply to be a BBB National Programs employee, contractor, or intern or to be an arbitrator for the BBB AUTO LINE or DPF Services programs, you submit your name, address and other contact information, and information about your qualifications. We use this information for processing your application and for contacting you in relation to your application. We do not share this information with any non-agent third parties.

6. When applying to or requesting information from BBB National Programs on behalf of a business.

BBB National Programs may collect contact and billing information from a business that enquires about becoming a National Partner or participating with an individual program operated by BBB National Programs (including BBB AUTO LINE, DPF Services, CARU, Cross-Border Privacy Rules Program, Privacy Recognition for Processors Program, Vendor Privacy Program, or Children’s Food and Beverage Advertising Initiative). This may include personal contact information about representatives of the business. We may contact these individuals with more information about our programs, events, and services. We do not share this information with any non-agent third parties, except as described in Section II below. To request to change the personal information associated with your business account, please reach out to the individual program with which you do business.

7. When representing a business in the NAD competitor challenge process.  

BBB National Programs may collect contact information from individuals (including outside counsel, if applicable) that participate in a National Advertising Division challenge, either on behalf of a company challenging a competitor’s advertising or having their advertising challenged. We use this information to contact the individuals throughout the challenge process. We may also contact these individuals with more information about our programs, events, and services. We do not share this information with any non-agent third parties.

8. When completing a privacy review as part of a certification or seal.

When pursuing a privacy certification (such as those provided by the Cross-Border Privacy Rules Program, Privacy Recognition for Processors Program, Vendor Privacy Program) or CARU’s COPPA safe harbor participation, your business will provide contact information to us about representatives of the business. During the course of a privacy review, this information may be processed by a third-party agent, WireWheel, through which we provide this service. Other non-personal business information will also be processed by WireWheel, on behalf of our programs, consistent with the terms of its privacy policy that apply to “Users” (https://wirewheel.io/wirewheel-privacy-notice/) and its User Terms of Service: https://wirewheel.io/terms-of-service/. Information collected during the course of a review will be processed consistent with the terms of the individual program Participation Agreement.

9. When settling an invoice.

BBB National Programs will use any billing information you have provided in order to contact you for payment of an invoice. In the process, we may ask for payment information, which will be entered directly into our third-party payment processor. BBB National Programs does not directly process or store payment information.

10. When signing up for a newsletter.

At certain points where your information is collected on our site, there may be a box where you may indicate you would like to be on a mailing list to receive information about BBB National Programs or an individual BBB National Programs program. This election box only appears in places where the service collecting your information maintains such lists. We do not sell mailing lists and this information is not shared with any non-agent third parties. You can remove your name from a BBB National Programs mailing list by utilizing the appropriate unsubscribe feature contained in the emails.

B. Information collected automatically through your use of BBB National Programs’ websites and services.

1. Device information.

Like most websites, BBB National Programs may automatically collect certain information from the device you use to visit our website, which we store in log files. This may include your browser type, device type, IP address, region or general geographical location from which your device is accessing the internet, operating system, unique device identifier, software version, and the domain name from which you accessed the site. We may rely on third-party agents to collect or process this analytic information. This information is used solely for our internal business purposes, including to improve the functionality of our site, diagnose problems, and generate statistical reports.

2. Aggregated usage information.

We collect information about how visitors use and interact with the site, including the date and time of site visits, device and browser information, the referring site URL, the areas or pages of the site visited, the amount of time spent viewing or using the site, and other click-stream or site usage data. We rely on third-party agents, including Google Analytics and Crazy Egg, to collect and process this analytic and usability information. This information is used solely for our internal business purposes, including to improve the functionality of our site, diagnose errors, generate statistical reports, analyze trends, understand and improve user experience, and identify aggregate user preferences.

To view an overview of the privacy practices of Google Analytics, please go here: https://support.google.com/analytics/answer/6004245. Google Analytics supports an optional browser add-on that—once installed and enabled—disables measurement by Google Analytics for any site a user visits. You can find the browser add-on here: https://tools.google.com/dlpage/gaoptout.

To view an overview of the privacy practices of Crazy Egg, please read the section of Crazy Egg’s privacy policy titled “Information Collected by or on Behalf of Our Clients via the Service” here: https://www.crazyegg.com/privacy. If you wish to opt out, Crazy Egg responds to “Do Not Track” signals issued by your browser. Please visit the following page for instructions on enabling the “Do Not Track” setting on your browser: https://www.crazyegg.com/opt-out.

3. Individual usage information.

With your consent, and if we have a business relationship with you or your organization, we may associate certain usage information as described in Section B2 above with known personal information, including your name, organization, and contact information. Along with this information, we also may associate email usage information, including the links you open in emails that you receive from us. We rely on a third-party agent, HubSpot, to collect and process this information. This information is used solely for our internal business purposes, including to improve the experience of our stakeholders by providing the most relevant and high quality content on our website and other media.

To view an overview of the privacy practices of HubSpot, please go here: https://legal.hubspot.com/product-privacy-policy. If you wish to adjust your preferences about our collection of individual usage information using HubSpot, please see the “Choices about your information” section below.

Please note that personal information about individual consumers (such as complaint information) is never associated with usage information, even if you opt in to cookies on our website.

C. Information collected by third parties and shared with BBB National Programs.

1. In the course of complaint resolution, conciliation, or arbitration.

BBB National Programs may receive information about you from businesses or organizations with which you have interacted for the purposes of facilitating the resolution of a pending complaint, conciliation, or arbitration proceeding. This may include your name, date of birth, account number, or other information used to verify your identity. This may also include account history information, your previous communications with the business or organization related to the matter in your complaint, or any other relevant information.

2. Participating business contact information.

A business participating in a program operated by BBB National Programs may share with BBB National Programs contact information for its employees or designated representatives. BBB National Programs will use this information only for the purposes of fulfilling the contract with the business. Unless the individual opts out, we may also use this information to notify them about our own programs, events, and related services.

II. Other Ways Information May Be Shared

We may use third-party agents to collect or process data on our behalf. Such contractors are obligated to not disclose or use your information for purposes other than for which it was originally collected or subsequently authorized.

BBB National Programs may also share information under the following circumstances:

• We respond to requests from governmental agencies or where required by law (such as by subpoena, investigative demand, court order, or regulation).

• We may share information with appropriate governmental or regulatory authorities, where warranted by a company’s failure to (i) participate in certain BBB National Programs self-regulatory programs including the Children’s Advertising Review Unit and the Digital Advertising Accountability Program; (ii) follow procedures or implement a decision of DPF Services; (iii) substantially comply with its CFBAI pledge or CCAI Core Commitments; or (iv) participate in or honor the recommendations of the National Advertising Division, Children's Advertising Review Unit, National Advertising Review Board, Electronic Retailing Self-Regulatory Program, or Digital Advertising Accountability Program.

• We may share information with appropriate persons or governmental authorities, where your communication suggests possible harm to others.

III. Choices about your information.

A. Mailing Lists

You may unsubscribe from our mailing lists or other routine email communications using the link included at the end of each message or by sending an email to privacy@BBBNP.org.

B. Individual Usage Information

To revoke your consent for our use of cookies and other tracking technologies to collect information about your individual use of our website and other media, as described in Section B3 above, please click the button below:

C. Your Ad Choices

BBB National Programs does not share data with third parties for interest-based advertising purposes. However, BBB National Programs adheres to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising, and commits to provide consumers with notice and choice about interest-based advertising. To learn more about interest-based advertising, click here. To opt out of future interest-based advertising, click here. You will still see ads, but they will not be tailored to your interests.

IV. Cookies or other persistent identifiers 

BBB National Programs and our third-party agents may use persistent identifiers such as cookies, embedded scripts, web beacons, pixel tags, or similar technologies to collect information about our visitors’ interactions with our site and other media. We use these identifiers to generate the data described in “aggregated usage information” above. With your consent, and if we have a business relationship with you or your organization, we also may associate this data with other known information about you, as described in “individual usage information” above.  This information is used to understand how visitors use our sites and provide better services to you, provide easier site navigation, access to forms, or to track analytics and certain statistical information that enables us to improve our site and provide you with more relevant content and information on our site and other sites.

You can still use BBB National Programs’ websites if you have set your browser to reject cookies or other tracking technologies, but there is a possibility that this will prevent you from viewing or accessing some of the features of our sites. At this time, we do not respond to “Do Not Track” signals issued by web browsers.

V. Security

Personal data that you provide to BBB National Programs is stored by BBB National Programs on servers located in third-party data centers in the United States with restricted access, that have implemented reasonable procedures to prevent unauthorized access to, and the misuse of, personal data. BBB National Programs restricts access to your personal data to authorized BBB National Programs employees, independent contractors and service providers who need to access the data in order to provide services in support of BBB National Programs operations and program services.

BBB National Programs has taken steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing personal information and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.

VI. International Transfers

If you are visiting our site from outside the United States, be aware that your information will be transferred to, and maintained on, computers located within the United States. The collection, use, retention and any other processing of your information will be governed by U.S. law and further by the specific jurisdictions within the United States where that information is stored, unless otherwise specified. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

VII. Changes to this Privacy Policy

We recognize our ongoing responsibility with regard to the privacy of individuals whose personal data we collect and process. If we embrace new data privacy practices or adopt new policies, we will update this Privacy Policy. In the event that we make material changes to this policy, we will notify affected individuals.

VIII. Inquiries about BBB National Programs’ Privacy Policy and Practices

If you have comments or concerns about this privacy policy or our privacy practices, you may contact us at privacy@BBBNP.org or by postal mail:

ATTN: Privacy Compliance
BBB National Programs
1676 International Drive, Suite 550
McLean, VA 22102