Date of Last Revision: June 29, 2018
Welcome to https://brightback.com (the “Site”) of Brightback Inc. (“Brightback”, “we”, “us” and “our”). This Site is operated by Brightback and has been created to provide information about our company and our customer retention services and related technologies and related services, including our applications for mobile devices (the “Platform, and together with the Site, the “Services”) to our Site visitors (“you”, “your”).
For the purpose of applicable data protection legislation and subject to the following sentence, the data controller of your personal data is our customer that has provided your Personal Data (defined below) to us and we are a data processor for such data controller. If this is the case, please direct your data privacy questions to your data controller, as your use of the Services is subject to that organization's policies. We are not responsible for the privacy or security practices of your data controller’s organization, which may be different than this policy.
1. Information We Collect:
- Personal Data That You Provide Through the Services:
- We collect Personal Data from you when you voluntarily provide such information to us. You may provide us with Personal Data when you:
- Create accounts for Services,
- Integrate third party accounts,
- Register for offers,
- Provide billing and payment information,
- Elect to receive marketing communications,
- Complete a survey,
- Receive customer support,
- Purchase or register to use the Platform, or
- Apply for a job.
- Personal Data that we collect includes your contact information (such as your name, email address, mailings address, or phone number), billing information (such as your credit card information, security code, and billing address), your IP address, and the information that you process on the Platform (such as names, titles, email addresses, mailing addresses, and phone numbers of your customers, leads, and contacts).
- In connection with the Platform, Brightback collects Personal Data of individuals as directed by its customers (“Customers”), and has no direct relationship with the individuals whose Personal Data it processes on behalf of such Customers. Brightback acknowledges that you have the right to access your Personal Data. If you are an employee or customer of one of our Customers and would like to correct, amend, or delete inaccurate data, please contact such Customer directly (the data controller). You may request to remove your Personal Data from our databases at firstname.lastname@example.org, and we will respond to that request within a reasonable timeframe.
- In connection with the Platform, Brightback collects Personal Data of individuals as directed by its customers (“Customers”), and has no direct relationship with the individuals whose Personal Data it processes on behalf of such Customers. If you are an employee or customer of one of our Customers and would like to correct, amend, or delete inaccurate data, please contact such Customer directly (the data controller). If, however, you request any such revisions to your personal data (including via email@example.com), we will respond to that request within a reasonable timeframe and notify the data controller.
- We ask that you not send us, and you do not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service or otherwise to us.
Information We Collect Through the Services
- The Services that you purchase or register to use may connect and transmit system, application, or product data to Brightback. This data may include, but is not limited to, operating system, system model, and IP address.
- Internet Protocol Address;
- Browser type;
- IP Address;
- Device type or ID:
- Device user ID;
- Browser language;
- Operating system;
- Referring site (site you visited before coming to the Site);
- Date and time of visit;
- URL of pages visited; and
- We may link this information to Personal Data to provide better services to you and to improve our product and services offerings. Most browsers allow you to remove and block cookies and web beacons. Please note that if you choose to erase or block cookies, you will need to re-enter your user ID and password to access certain parts of the Site. You may also notice that you will be served only generic information not tailored to your specific interests. In addition, if you block cookies, you may not be able to use certain Services features or take full advantage of the Services.
- Many Internet browsers allow users to send a “Do Not Track” signal to websites they visit. Currently, there is no consensus on the meaning of “Do Not Track” or similar signals, and the Services have no mechanism to respond to such a signal.
- In the course of using the Services, you or someone else in your organization may provide us with information about your systems infrastructure and access to your systems infrastructure. In addition, Brightback may discover this information by analyzing additional parts your systems infrastructure that you did not explicitly input into the Platform.
Our website uses the following types of cookies for the purposes set out below:
|Type of cookies||Purpose|
These cookies are essential to provide you with services available through our website and to enable you to use some of its features (e.g. they allow you to log in to secure areas of our website and help the content of the pages you request load quickly). Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our website to remember choices you make when you use our website, [such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our website which you can customize]. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our website.
|Analytics and performance cookies||
These cookies are used to collect information about traffic to our website. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. We use this information to help operate our website more efficiently, to gather broad demographic information and to monitor the level of activity on our website.
We use Google Analytics and other third party analytics services for this purpose. Google Analytics uses its own cookies. It is only used to improve how our website works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB].
|Targeted and advertising cookies||
These cookies track your browsing habits to enable us to show marketing which is more likely to be of interest to you. These cookies use information about your browsing and email history to group you with other users who have similar interests, and allow more relevant third party emails and browser-based offers to be provided to you (with our permission).
Information We Collect From Other Sources
- We sometimes obtain information from other sources, such as mergers and acquisitions, data brokers, or commercial lists, and merge this with information we have previously collected.
- We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests.
2. How We Use Information We Collect
We use Personal Data to conduct business, provide information and support for products and services, better understand your needs and interests, refine and develop our business, improve services, personalize communications and ensure a quality experience for users of the Services. For example, we may use your information to:
- Communicate, interact and build our relationship with you;
- Contact you with relevant promotions and information about Brightback and affiliated third-parties;
- Process, fulfill and follow up on transactions and requests for products, services, support, training and information;
- Send you reminders about the expiration of your subscriptions (trial or paid) for Services;
- Create and maintain an account and register Services;
- Bill and accept payment from you for Services;
- Engage in market research;
- Measure, analyze and improve our products and services, the effectiveness of our Site or Services, and our advertising and marketing;
- Notify you about updates to our blogs;
- Monitor your use of the Services;
- Tell you when updates and new product versions are available;
- Personalize content and advertising;
- Help identify and communicate offers of products, programs and services that may be of interest to you;
- Send “refer-a-friend” email on your behalf with your consent;
- Consider your employment application;
- Comply with legal requirements;
- Enforce our terms of service, and prevent fraud and other prohibited or illegal actives;
- Provide agreed upon diagnostic, monitoring and management services; or
- Better communicate with you.
We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you make any comments on a blog or forum associated with your Site, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.
We may create anonymous data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you (“Anonymous Data”). We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Site and Services. If you registered with us, the clicking of the “Continue” button or continuing to use our Service indicates your consent to our processing of your personal data in order to access our Service or view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this policy, please do not use our website. When fulfilling our contractual obligations to our customers (i.e., the data controllers), we have a legitimate interest in processing Personal Data for such contractual purposes.
We may use automated decision-making and/or profiling in regard to your personal data for some services and products, for example making offers based on past purchasing patterns, geography, language, or industry. You can request a manual review of the accuracy of an automated decision that you are unhappy with or limit or object to such automated decision-making and/or profiling by contacting us at firstname.lastname@example.org.
3. How We Share and Disclose Personal Data
We may share or disclose your Personal Data as follows:
- To third parties that you designate to receive such information, including other websites and services.
- To corporate subsidiaries we own or control to support their business and marketing processes.
- To our service providers and suppliers, who are acting and using your information on our behalf to provide the Services and help us with our business activities such as (processing your payments, providing customer service, or hosting our Platform). These companies are authorized to use your personal information only as necessary to provide these services to us. Transfers of personal data to subsequent third parties are covered by the services agreements between us and our customers.
- We may enter into agreements with companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Site (“Third Party Companies”). A Third Party Company may want access to Personal Data that we collect from its customers. As a result, we may disclose your Personal Data to a Third Party Company; however, we will not disclose your Personal Data to any Third Party Company for the Third Party Company’s own direct marketing purposes, unless you have “opted-in” by following the instructions we provide to allow such disclosure. If you have opted-in to receive e-mail communications from a Third Party Company and later wish to discontinue receipt of these e-mails, please contact the Third Party Company directly to update your preferences. The privacy policies of these Third Party Companies may apply to the use and disclosure of your Personal Data that we collect and disclose to such Third Party Companies. Because we do not control the privacy practices of Third Party Companies, you should read and understand their privacy policies.
- Based on a good faith belief that such disclosure is necessary to protect the rights or safety of any person or entity.
- Based on a good-faith belief that disclosure is necessary to respond to judicial process, valid government inquiry, or is otherwise required by law such as to comply with a subpoena, bankruptcy proceedings, or similar legal process.
- In the event that Brightback or any of its assets are acquired, your information may be transferred with the company or the asset.
- To other third-parties for purposes to which you have allowed or consented (such as an authorized reseller).
- When posted by you or an authorized third-party to our wikis, forums, blogs, message boards, chat rooms and other social networking environments.
Personal Data that we collect from you, may be transferred to, stored at and processed by us and our affiliates outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our site and service, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
In an ongoing effort to better understand and serve the users of the Services, Brightback often conducts research on its 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 Brightback may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Brightback may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
4. Your Rights Regarding Your Personal Data
You have the following rights in your Personal Data:
- Access. You may access the data we hold about you at any time via your account or by contacting us directly.
- Amend. You can also contact us to update or correct any inaccuracies in your personal data.
- Move. Your data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
Upon request Brightback will provide you with information about whether we hold any of your Personal Data. To keep your Personal Data accurate, current, and complete, please contact us as specified below on “Contact Us ”section, or contact your data controller. We will take reasonable steps to update or correct and delete Personal Data in our possession that you have previously submitted via the Services or that the data controller has provided to us, but in all cases within the requirements specified by applicable law.
We will retain personal data we process on behalf of our Customers for as long as needed to provide services to our Customers. Brightback will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you wish to subscribe to our marketing communications, we will use your name and email address to send communications to you. You may elect to stop receiving our marketing emails by following the unsubscribe instructions included in such emails, or you may contact us at email@example.com.
5. Children’s Privacy
Use of the Services is only available to individuals who are of legal age to contract in their applicable jurisdiction. The Services are not directed to children under 13 years of age. If our policy changes, we will obtain consent from a parent or guardian before we knowingly collect data from anyone under the age of 13.
6. Links to Other Web Sites:
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. You acknowledge and agree that no Internet or email transmission is ever fully secure or error free. You agree to take special care in deciding what information you send to us via email. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
9. Contact Us