Effective date: July 26, 2019
We gather various types of Personal Data from our users, as explained in more detail below, and we use this Personal Data internally in connection with our Services, including to personalize, provide, and improve our Services, to allow you to set up a user account and profile (if applicable), to contact you and allow other users with whom you have voluntarily interacted on discussion boards or chat areas on the Services to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Data with third parties, but only as described below.
We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at email@example.com.
What Information does Brim Data Collect?
Information You Provide to Us
We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Data including, without limitation, the following:
- First and Last Name,
- Email address,
- Phone Number, and
- Payment Information.
Certain information may be required to register with us or to take advantage of some of our features.
We may communicate with you if you’ve provided us the means to do so. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by contacting us at firstname.lastname@example.org or by following the opt-out instructions contained in any emails from us.
Information Collected Automatically
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include the following:
- IP address,
- Geolocation data,
- Device Identification,
- Web Browser Information,
- Page View Statistics, and
- Usage Information.
We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services - for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
Information Collected From Other Websites and Do Not Track Policy
Information Collected from Third Parties
- Some third parties such as our business partners and service providers provide us with Personal Data about you, such as the following: Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
How do we use Personal Data?
We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:
- Create and manage user profiles and content (if applicable)
- Communicate with you about the Services, including Service announcements or updates
- Provide support and assistance for the Services
- Comply with our legal or contractual obligations
- Resolve disputes
- Protect against or deter fraudulent, illegal or harmful actions
- Respond to user inquiries and requests
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our agreement(s) with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
- First and Last Name
- Email address
- Phone Number
- Payment Information
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
First and Last Name
Examples of these legitimate interests include:
Operation and improvement of our business, products and Services
Marketing of our products and Services
Provision of customer support
Protection from fraud or security threats
Compliance with legal obligations
Completion of corporate transactions
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Will Company Share Any of the Personal Data it Receives?
We do not rent or sell your Personal Data in personally identifiable form to anyone, except as expressly provided below. We may share your Personal Data with third parties as described in this below:
Information that’s been de-identified: We may de-identify your Personal Data so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual.
Advertisers: We may engage advertisers and/or merchant partners for marketing or promotional purposes.
Affiliated Businesses: In certain situations, businesses or third party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Data with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.
Our Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Data we share with them beyond what is necessary to assist us.
User Profiles and Submissions: Certain user profile information, including your name, location, and any video or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account privacy settings may allow you to limit the other users who can see the Personal Data in your user profile and/or what information in your user profile is visible to others. Please remember that any content you upload to your public user profile, along with any Personal Data or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments.
Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Data could be one of the assets transferred to or acquired by a third party.
Protection of Company and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others.
Is Personal Data about me secure?
Your account or portions of the Service may be protected by a password for your privacy and security. If so, you must prevent unauthorized access to your account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. Our security measures vary based on the sensitivity of the Personal Data we collect, process and store and the current state of technology.
We endeavor to protect the privacy of your account and other Personal Data we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
What Personal Data can I access?
Through your account settings (if applicable), you may access, and, in some cases, edit or delete the following information you’ve provided to us:
- name and password
- email address
- user profile information
The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at email@example.com.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at firstname.lastname@example.org.
What rights do I have regarding my Personal Data?
IF YOU ARE A RESIDENT OF THE EU, SWITZERLAND, UNITED KINGDOM, LICHTENSTEIN, NORWAY, OR ICELAND, YOU HAVE CERTAIN RIGHTS WITH RESPECT TO YOUR PERSONAL DATA, INCLUDING THOSE SET FORTH BELOW. FOR MORE INFORMATION ABOUT THESE RIGHTS, OR TO SUBMIT A REQUEST, PLEASE EMAIL INFO@BRIMDATA.COM. PLEASE NOTE THAT IN SOME CIRCUMSTANCES, WE MAY NOT BE ABLE TO FULLY COMPLY WITH YOUR REQUEST, SUCH AS IF IT IS FRIVOLOUS OR EXTREMELY IMPRACTICAL, IF IT JEOPARDIZES THE RIGHTS OF OTHERS, OR IF IT IS NOT REQUIRED BY LAW, BUT IN THOSE CIRCUMSTANCES, WE WILL STILL RESPOND TO NOTIFY YOU OF SUCH A DECISION. IN SOME CASES, WE MAY ALSO NEED YOU TO PROVIDE US WITH ADDITIONAL INFORMATION, WHICH MAY INCLUDE PERSONAL DATA, IF NECESSARY TO VERIFY YOUR IDENTITY AND THE NATURE OF YOUR REQUEST.
- Opt Not to Disclose: You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. When you update information, however, we may maintain a copy of the unrevised information in our records.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about Brim’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to email@example.com, and we will try to resolve your concerns.