Effective as of March 19, 2019
A reference to “Brightidea”, “we”, “us”, “our”, or the “Company” is a reference to Brightidea, Inc.
Processing Activities Covered
- Visiting our websites;
- Visiting our offices;
- Receiving communications from us;
- Registering for our events;
- Participating in our Innovation community (ideas.brightidea.com).
What Personal Data do we collect?
The Personal Data that we collect directly from you may include the following:
- If you express an interest in obtaining additional information about our services, request customer support, use our “Contact Us” or similar features, register to use our websites, sign up for an event or webinar, or download certain content, we generally require you to provide us with your contact information, such as your name, job title, company name, address, phone number, email address, or username and password;
- If you register for an event, we may also require you to provide us with financial and billing information, such as billing name and address and credit card number;
- If you register for an online community that we host, we may ask you to provide a username, email address, photo and/or biographical information such as your occupation, social media profiles, company name, and areas of expertise;
- If you use and interact with our websites, we automatically collect log files and other information about your device and your usage of our websites through cookies, web beacons or similar technologies, such as IP addresses or other identifiers, which may qualify as Personal Data;
- If you visit our offices, you may be required to register as a visitor and to provide a copy of your government issued identification and the date and time of arrival.
Personal Data we collect from other sources:
We also collect information about you from other sources, including third parties from whom we have purchased Personal Data, and combine this information with Personal Data provided by you. This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. In particular, we collect Personal Data from the following sources:
- Business contact information, including mailing address, job title, email address, phone number, web use behavior data, IP addresses, social handles, LinkedIn URL and third-party data providers for the purposes of targeted advertising, delivering relevant email content, event promotion and profiling;
- If you participate in our Innovation online community, we use your email address to inform you of program changes or additional security requirements.
What device and usage data we process
We use information gathering tools, such as log files, cookies, web beacons and similar technologies to automatically collect information, which may contain Personal Data, from your computer or mobile device as you navigate our websites or interact with emails we have sent you.
We gather certain information via log files. This collected information includes your Internet Protocol (IP) address (or proxy server), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and data/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our websites and to guarantee it security and continued proper functioning. We also collect IP addresses from users when they log into services as part of our security features.
Cookies, web beacons and other tracking technologies
Opt-Out from the collection of device and usage data
You may opt-out from the collection of device and usage data by managing your cookies at the individual browser level. In addition, if you wish to opt-out of interest-based advertising click here, or if located in the European Union click here. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the websites.
Please note the opting-out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as information about your subscriptions or event registrations, service announcements or security information.
Upon a request submitted to email@example.com, Brightidea will provide website visitors at no cost with access to their personal information that we have on record and the ability to complete, update or remove such information.
Social Media Features
Our websites may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social Media Features are hosted by the respective social media network and may receive information that you have visited our websites from your IP address. If you are logged into your social media account, it is possible that the respective social media network can link your visit of our websites with your social media profile.
Purposes for which we process Personal Data and the legal basis on which we rely
We collect and process your Personal Data for the purposes and on the legal basis identified in the following:
- Promoting security of our websites: We will process your Personal Data by tracking use of our websites, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity, as well as violations of and enforcement of our terms and policies;
- Managing user registrations: We will process your Personal Data by managing your user account for the purpose of performing the contract with you according to any applicable terms of service;
- Handling contact and user support requests: If you fill out a “Contact Me” web form, request user support, or if you contact us by other means, we will process your Personal Data for the performance of our contract with you and to the extent it is necessary for the purpose of our legitimate interests to fulfill your request and communicate with you;
- Managing event registrations and attendance: We will process your Personal Data to plan and host the event or webinar, including related communications with you, on basis of the performance of our contract with you;
- Managing payments: If you have provided financial information, we will process your respective Personal Data to collect payments to the extent this is necessary for completing transactions with you under the contract with you.
- Developing and improving our websites: We will process your Personal Data to analyze trends, track your usage of our websites and interactions with emails to the extent this is necessary for our legitimate interests to develop and improve our websites and to provide our users with more relevant and interesting content;
- Managing office visitors: We will process your Personal Data for security reasons, to register who visited our offices.
- Displaying personalized advertisements and content: We will process your Personal Data to conduct market research, advertise to you, provide personalized information about us on and off our websites, and other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interests to advertise our websites or, where necessary, to the extent you have provided your prior separate consent;
- Sending marketing communications: We will process your personal Data to send you marketing information, product recommendations and other non-transactional communications, such as marketing newsletters, about us and our partners, including information about our products, promotions or events as necessary for our legitimate interests to conduct direct marketing or to the extent you have provided your prior separate consent;
- Complying with legal obligations: We will process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights, and is necessary for our legitimate interests to protect against misuse or abuse of our websites, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with judicial proceedings, court order or legal process, and/or respond to lawful requests.
Who do we share Personal Data with?
We may share your Personal Data with the following recipients:
- Our contracted service providers which provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment;
- If you attend an event or webinar organized by us, we may share your information with sponsors of the event if you consent to such sharing via the event registration form;
- With third-party social networks, advertising networks and websites, which usually act as separate controllers, so that Brightidea can market and advertise on third-party platforms and websites;
- With partner organizations and companies for service, sales, support, and marketing purposes;
- Any Personal Data or other information you choose to submit in communities, forums, blogs, or chat rooms on our websites may be read, collected, and/or used by others who visit these forums.
International transfer of information collected
Your personal data may be collected, transferred to and stored by us in the United States.
Therefore, your Personal Data will be processed outside the EEA. We will ensure that such recipients offer an adequate level of protection, for example Privacy Shield or by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR).
Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us as described in the “Contacting Us” section below and we will take steps to delete such Personal Data from our systems.
How long do we keep your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of the collection. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of your Personal Data, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means, as well as the applicable legal requirements.
After expiry of the retention periods, your Personal Data will be deleted. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of the data.
Your rights relating to your Personal Data
You have certain rights regarding your Personal Data, subject to local data protection laws. These may include the following rights:
- to access your Personal Data held by us (right to access);
- to rectify inaccurate Personal Data and ensure it is complete (right to rectification);
- to erasure/delete your Personal Data to the extent permitted by other legal obligations (right to erasure; right to be forgotten);
- to restrict our processing of your Personal Data (right to restriction of processing);
- to transfer your Personal Data to another controller to the extent possible (right to data portability);
- to object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object);
- not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision Making”); Automated Decision Making currently does not take place on our websites;
- to the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
How to exercise your rights
To exercise your rights, please contact us in accordance with the “Contacting Us” section below. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive.
In addition, if you have registered for an account with us, you may generally update your user setting and profile by logging into the applicable websites with your username and password and editing your settings or profile. To discontinue your account, and/or request return or deletion of your Personal Data and other information associated with your account, please contact us.
Your rights relating to Customer Data
As described above, we may also process Personal Data in the role of a processor. If your data has been submitted to us by a Brightidea client and you wish to exercise any rights you may have under the applicable data protection laws, please inquire with our client directly. Because we may only access our client’s data upon instruction from the respective client, if you wish to make your request directly with us, please provide the name of the Brightidea client who submitted your data when you contact us. We will refer your request to that client, and will support them as needed in responding to your request within a reasonable timeframe.
GDPR Recourse (for EU individuals)
EU individuals who wish to file a GDPR complaint have the right to go directly to their EU Data Protection Authority (DPA). Individuals wishing to do so may locate the appropriate DPA by going to https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
We take precautions including organizational, technical and physical measures, to help safeguard against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the Personal Data we process or use.
While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. If you have questions about the security of our websites, please contact us via the “Contacting Us” section below.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Brightidea is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Brightidea complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. Pursuant to the Privacy Shield, Brightidea remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
Pursuant to the Privacy Shield, EU and Swiss individuals have the right to access their data. Upon a request submitted to firstname.lastname@example.org, Brightidea will provide website visitors at no cost with access to their personal information that we have on record and the ability to complete, update or remove such information.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Brightidea is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Brightidea may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, Brightidea commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Brightidea at: email@example.com. Written inquiries may be addressed to:
Attn: Privacy Officer
25 Pacific Avenue
San Francisco, CA 94111 – USA
Brightidea has further committed to refer unresolved Privacy Shield complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Attn: Privacy Officer
25 Pacific Avenue
San Francisco, CA 94111 – USA
Or send an email to firstname.lastname@example.org
Please include the following in your request:
- First and Last Name
- Email address
- Are you a Brightidea client?
- Details of your question, comment or request
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority.