Privacy Policy
Effective as of December 11, 2019
BrightSign Privacy Policy
California Residents: Click here for the California Notice of Collection
Welcome to the website (the “Site”) of BrightSign LLC (“BrightSign”, “we”, “us” and/or “our”). This Site is operated by BrightSign and has been created to provide information about our company and its products and services, including its cloud-based services (the “Products”) to you as a visitor to our Site or user of our Products or otherwise in your interactions with us (“you” and/or “your”). This Privacy Policy sets forth BrightSign’s policy with respect to information, including personal data and personal information (as such terms are defined in applicable law, and collectively referred to herein as “Personal Data”), that is collected from you by us.
By providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of BrightSign and the authorized third parties referred to herein located in the United States.
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:
Cookies
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 to enter a password more than once during a visit to the Site;
- We use cookies from Google Analytics, a web analytics service provided by Google Inc. (“Google”). The information collected by Google (including your internet protocol (IP) address) will be transmitted to and stored by Google on servers in the United States. Google will use this information on our behalf for the purpose of evaluating your use of the Site, compiling reports on the Site activity, and providing further services to us relating to the Site usage. Learn more about Google Analytics’ privacy practices, and see a copy of Google’s privacy policy, at the following link: Google Analytics. You can prevent your data from being collected by Google Analytics on our Site by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser at the following link: Opt Out
If you are based in the European Economic Area, when you first visit the Site, you will be asked to consent to the use of cookies on the Site in accordance with this Privacy Policy, and if you accept, we will store cookies on your computer.
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:
We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site’s features. As noted above, on most web browsers you may refuse the use of cookies by selecting the appropriate settings; however, please note that if you do this you may not be able to use the full functionality of the Site.
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.
Log Data
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
To provide the service and respond to requests: BrightSign uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by Email, we will use the Personal Data you provide to answer your question or resolve your problem. If you provide Personal Data to purchase, register, or use a Product, we will use your Personal Data to conduct activities related to your request, including delivering to you the Product(s) that you purchased, maintaining your account, contacting you regarding your use of the Products and/or the Site, or notifying you of important changes to our services and/or the Site. For EU data subjects, such use is also necessary to respond to or implement your request.
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.
To analyze, administer, support, and improve use of the Site and our services: We use data relating to your use of and interaction with the Site and our Products, including information that we obtain through cookies, to analyze, administer, support and improve your access to and use of the Site and our services. We often conduct research on our customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and BrightSign may share this aggregate data with its affiliates, agents and business partners. BrightSign may also disclose aggregated user statistics in order to describe our Products to current and prospective business partners, and to other third parties for other lawful purposes. This aggregate information does not identify you personally. For EU data subjects, this use of your Personal Data is necessary for our legitimate interests in understanding how the Site and our services are being used by you and to improve your experience of it. For some cookies placed through our Site, we rely on your consent – please read the “Cookies” section above for more information on how we use cookies and other tracking technologies.
If BrightSign intends to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time during which the Personal Data is collected, or as otherwise prescribed by the applicable law.
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.
Affiliates: We may also share your Personal Data with our affiliates for purposes consistent with this Privacy Policy.
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
Scope:
This section applies solely to EU data subjects (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). Our Privacy Policy describes why and how BrightSign collects, uses and stores your Personal Data, the lawful basis on which your Personal Data is processed, and what your rights and our obligations are in relation to such processing (please see “Your Rights” section below).
Data Controller:
BrightSign is the data controller for processing your Personal Data. Please see the Contacting BrightSign section below to find out how to contact us.
Your Rights:
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.
Legitimate Interest:
“Legitimate interests” means the interests of BrightSign in conducting and managing our organization. For example, we have a legitimate interest in processing your Personal Data to analyze how the Site and our products and services are being used by you, to prevent fraud or criminal activity, misuses of our products or services, to ensure the security of our IT systems, architecture and networks, and to meet our corporate and social responsibility objectives, as described in this Privacy Policy. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent, or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section above.
Data Transfers:
BrightSign uses service providers (described above) to operate our business and our relationship with you. When you use our Site and Products, you acknowledge and agree that your Personal Data will be transmitted to our and our service providers’ servers in the United States to provide you with the services that you requested, administer our contract with you or to respond to your requests as described in this Privacy Policy. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data out of the EEA, we will take steps to ensure that your rights continue to be protected.
Data Retention:
We will keep your Personal Data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by law, whichever is the longer.
YOUR CHOICES
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.
EXCLUSIONS
This Privacy Policy does not apply to any Personal Data collected by BrightSign other than Personal Data collected through the Site or Products. This Privacy Policy shall not apply to any unsolicited information you provide to BrightSign through the Site or Products or through any other means (without prejudice to your rights under the applicable law). This includes, but is not limited to, information posted to any public areas of the Site, such as forums (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and BrightSign shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.
CALIFORNIA NOTICE OF COLLECTION
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”)).
Categories of personal information we collect. Throughout our Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about our users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect as defined by California law. The categories we collect depending on the types of services you use are: Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); internet or other network or device activity (such as browsing history or app usage); general information; professional or employment related data; inference data about you (e.g., the additional products and services we think you may be interested based on prior purchases or usage data); and other information that identifies or can be reasonably associated with you.
How we source, use, and share these categories of personal information. We source, use, and share with third parties the categories of personal information we collect from and about you consistent with the various business and operational purposes we discuss throughout our Privacy Policy and for the business and operational purposes of our service providers in accordance with the CCPA. See the “Our Use of Your Personal Data and Other Information” and “Our Disclosure of Your Personal Data and Other Information” section(s) in our Privacy Policy for more information.
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:
- Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. Such information is also set forth in our Privacy Policy.
- 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.
CHILDREN
BrightSign does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Site or Products. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data through the Site or Products without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to BrightSign through the Site or Products, please contact us as indicated in the Contacting BrightSign section at the end of this document, and we will endeavor to delete that information from our databases.
THIRD PARTY SITES AND PRODUCTS
This Privacy Policy applies only to the Site and Products. The Site or Products may contain links to or otherwise interact with other web sites or products not operated or controlled by BrightSign (the “Third Party Sites/Products”), including third party add-ons, applications and other software that could track your usage or collect Personal Data. The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third-Party Sites and not by this Privacy Policy. We suggest contacting those third parties directly for information on their privacy practices and policies.
SECURITY
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.
CHANGES TO BRIGHTSIGN’S PRIVACY POLICY
The Site, our Products and our business may change from time to time. As a result, at times it may be necessary for BrightSign to make changes to this Privacy Policy. BrightSign reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Site or Products after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
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 privacy@brightsign.biz or by post at:
BrightSign LLC
Attention: Privacy
P.O. Box 320250
Los Gatos, CA 95032-0104