Effective as of Dec 11, 2019
When you interact with us through our Site or Products, we collect Personal Data and other information from you, as further described below:
Personal Data That You Provide: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, create a BrightSign Network account (e.g. name, Email address, and password), respond to one of our surveys (e.g. name, Email address), purchase a Product (e.g. name, Email address, and shipping address), register your Product (name, Email address, and shipping address), communicate with customer service (e.g. name, Email address, phone number), provide information at a conference or event (e.g., name, and business or personal contact information), or otherwise use certain Products. In order to have access to certain Products and/or to purchase certain items, you may be required to provide credit card data or other acceptable payment information to our payment service provider.
Information Collected by Others: We may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other parties. We use this information to supplement the information that we collect directly from you.
Automatically Collected Data: When you interact with BrightSign through the Site or any Product, we receive and store certain information, which is collected passively using various technologies, as described below:
In operating the Site, we use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. In particular:
- Our Site may set a cookie on your browser that allows you to access the Site without needing enter a password more than once during a visit to the Site;
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org.
When you visit our Site or use the Products, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data may include web pages visited, browser type and settings, device type, length of visit, the date and time of your request, and product features you use. The Site also automatically captures your Internet Protocol (“IP”) address (from which we determine the country you are connecting from at the time you visit the Site). BrightSign uses IP addresses to analyze trends, administer the Site, track user movement, ensure the security of your interaction with the Site and gather broad demographic information for aggregate use.
OUR USE OF YOUR PERSONAL DATA AND OTHER INFORMATION
Marketing purposes: BrightSign and its affiliates may use your contact details to contact you in the future to tell you about products or services we believe will be of interest to you, as well as upcoming events or other promotions. If we do so, each communication we send you will contain instructions permitting you to "opt-out" of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated in the Contacting BrightSign section at the end of this document.
Where required by applicable law (for example, if you are an EU data subject), we will only send you marketing information by email if you consent to us doing so at the time you provide us with your Personal Data (and such consent will be our legal basis for processing your Personal Data for such purpose). When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you or by contacting us as indicated below.
Aggregate/Anonymous Data. We may aggregate and/or anonymize any personal data we collect from and about you so that such information can no longer be linked to you or your device (“Aggregate/Anonymous Data”). We may use Aggregate/Anonymous Data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties.
OUR DISCLOSURE OF YOUR PERSONAL DATA AND OTHER INFORMATION
We share your Personal Data in the circumstances discussed below:
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Agents, Consultants and Other Service Providers: BrightSign, like many businesses, sometimes hires other companies to perform certain business-related functions or work for BrightSign to provide the Products to you. These parties may include Email automation services, hosting and cloud computing service providers, payment processors, customer service, website analytics companies, providers of CRM, and marketing and sales software solutions. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. Pursuant to our instructions, these parties may access, process or store Personal Data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.
Legal Requirements: BrightSign may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of BrightSign, (iii) act in urgent circumstances to protect the personal safety of users of the Site or Products or the public, or (iv) protect against legal liability.
EU DATA SUBJECTS
BrightSign is the data controller for processing your Personal Data. Please see the Contacting BrightSign section below to find out how to contact us.
Subject to applicable law, you have the following rights in relation to your Personal Data:
- Right of access:If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details (this process requires that we confirm your identity and EU citizenship). If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification:If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to erasure:You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
- Right to restrict processing:You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are relying on a legitimate interest to process your Personal Data -- unless we demonstrate compelling legitimate grounds for the processing or
- If we are processing your Personal Data for direct marketing.
- Right to withdraw consent:If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
- Right to lodge a complaint with the data protection authority:If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
You may exercise your rights by contacting us as indicated in the Contacting BrightSign section at the end of this document.
You can visit certain portions of the Site and use certain portions of the Products without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain portions of the Site or Products.
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity and have not engaged in such activity in the past twelve months from the effective date of this Policy.
CCPA Rights Disclosure. If you are a California resident, the CCPA allows you (or an authorized agent acting on your behalf) to make certain requests related to your personal information. Specifically, the CCPA allows you to request us to:
- Provide access to and/or a copy of certain personal information we hold about you.
- Delete certain personal information we have about you.
- Provide you with information about the financial incentives that we offer to you, if any.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request. In doing so, we may request information from you so that we can match two or more data points provided by you with data points maintained by us. If we are unable to verify you through the foregoing methods, we shall have the right, but not the obligation, to request additional information from you. If you would like further information regarding your legal rights under California law or would like to exercise any of them, or if you are an authorized agent making a request on a user’s behalf, please contact us at the contact information listed below and include “CCPA Consumer Request” in the subject. A web intake form will be provided to you after your initial request.
Shine the Light Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
PRIVACY INFORMATION FOR NEVADA RESIDENTS
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined by Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us using the contact information provided below, and including “NV Sale Opt Out Request” in the subject line. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
THIRD PARTY SITES AND PRODUCTS
BrightSign takes steps to protect the Personal Data provided via the Site and Products from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, Email or messages sent to or from the Site or Products may not be secure. Therefore, you should take special care in deciding what information you send to us. Please keep this in mind when disclosing any Personal Data to BrightSign via the Internet.
OTHER TERMS AND CONDITIONS
Your access to and use of the Site is subject to the Terms and Conditions at www.brightsign.biz/, and your use of any Product is subject to the applicable terms and conditions for such Product.
ACCESS TO INFORMATION; CONTACTING BRIGHTSIGN
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Site or Products.
You may contact us by Email at firstname.lastname@example.org or by post at:
983-A University Ave.
Los Gatos, CA 95032