Privacy Policy

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Services
  • Creating and managing your account or other user profiles
  • Providing you with the products, services or information you request
  • Meeting or fulfilling the reason you provided the information to us
  • Providing support and assistance for the Services
  • Improving the Services, including testing, research, internal analytics and product development
  • Personalizing the Services, website content and communications based on your preferences
  • Doing fraud protection, security and debugging
• Marketing the Services
  • Marketing and selling the Services
• Corresponding with You
  • Responding to correspondence that we receive from you
  • Contacting you when necessary or requested
  • Sending emails and other communications according to your preferences

Other Permitted Purposes for Processing Personal Data

In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process; preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Brightseed or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You
  • When you provide such information directly to us
  • When you create an account or use our interactive tools and Services
  • When you voluntarily provide information in free-form text boxes through the Services
  • When you send us an email or otherwise contact us
  • When you use the Services and such information is collected automatically through Cookies
• Third Parties
  • Vendors: We may use analytics providers to analyze how you interact with the Services
  • Advertising Partners: We receive information about you from vendors who assist us with marketing
  • Third-Party Credentials: If you sign in through a third-party site or service

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed below:

• Service Providers: Hosting, technology and communication providers; Analytics providers; Security and fraud prevention consultants; Support and customer service vendors; Product fulfillment providers
• Advertising Partners: Ad networks; Marketing providers
• Parties You Authorize, Access or Authenticate: Third parties you access through the services

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Other Permitted Purposes for Processing Personal Data" section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect. We may use such data and disclose it with third parties for our lawful business purposes, provided that we will not disclose such data in a manner that could identify you.

Tracking Tools, Advertising, and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services.

Please note that because of our use of Cookies, the Services do not support "Do Not Track" requests sent from a browser at this time.

We use the following types of Cookies:

• Essential Cookies: Required for providing you with features or services that you have requested
• Functional Cookies: Used to record your choices and settings, maintain your preferences over time
• Performance/Analytical Cookies: Allow us to understand how visitors use our Services
• Retargeting/Advertising Cookies: Collect data about your online activity to provide relevant advertising

You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature. For more information, visit www.allaboutcookies.org.

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data.

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.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at info@brightseed.com.

State Law Privacy Rights

California Resident Rights

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 info@brightseed.com.

Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications that you do not wish such operators to track certain of your online activities. Our Services do not support Do Not Track requests at this time.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

European Union, United Kingdom, and Swiss Data Subject Rights

If you are a resident of the European Union ("EU"), United Kingdom ("UK"), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the "GDPR") with respect to your Personal Data.

You have certain rights with respect to your Personal Data, including:

• Access: You can request more information about the Personal Data we hold about you and request a copy
• Rectification: If you believe any Personal Data we hold is incorrect or incomplete, you can request correction
• 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, you have the right to withdraw at any time
• Portability: You can ask for a copy of your Personal Data in a machine-readable format
• Objection: You can contact us to object to further use or disclosure of your Personal Data
• 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 with the supervisory authority of your country

To submit a request, please email us at info@brightseed.com with the phrase "Privacy Rights Request" in the subject line.

Transfers of Personal Data

The Services are hosted and operated in the United States ("U.S.") through Brightseed and its service providers. By using the Services, you acknowledge that any Personal Data about you is being provided to Brightseed in the U.S. and will be hosted on U.S. servers, and you authorize Brightseed to transfer, store and process your information to and in the U.S., and possibly other countries.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: