Privacy Policy

This Privacy Policy describes how Brightside Benefit, Inc. (“Brightside,” “we”, “us”) collects and processes Personal Information.

 

Our hope is that Brightside becomes your go-to place for financial questions.  We aim to provide unbiased financial information, options and services that you can use to improve your financial health through GoBrightside.com, the Brightside mobile application (the “Brightside App”) and any affiliated website or application in which this Privacy Policy is posted or specifically referenced (collectively, “Services”).

Your privacy is important to us.  Please read this Privacy Policy to learn about the information that BRIGHTSIDE collects from OR ABOUT you and how BRIGHTSIDE uses that information.  WHEN YOU SUBMIT INFORMATION TO BRIGHTSIDE, YOU CONSENT TO THE PROCESSING OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY AND TO OUR TERMS OF SERVICE [LINK].

In this Privacy Policy, to “process” means to perform any operation on Personal Information (defined in Section 3 below), whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying.

 

1.  WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy applies to information collected by or through the Services, as well as information that you provide or we collect through your text messages or when you engage by telephone with one of our financial assistants (each, a “Brightside Assistant”). 

YOUR EMPLOYER MAY PROVIDE INFORMATION TO US.  THIS PRIVACY POLICY COVERS BRIGHTSIDE’S USE OF INFORMATION THAT YOUR EMPLOYER PROVIDES TO US.  AS NOTED BELOW, WE UPLOAD THE INFORMATION THAT YOUR EMPLOYER SHARES WITH US TO YOUR BRIGHTSIDE ACCOUNT AND USE IT AS DESCRIBED IN THIS PRIVACY POLICY.  Please contact your employer if you have questions about the information that your employer shares with us.

This Privacy Policy does not apply to information that is collected directly from you by any third-party website, application or other online service that you access through the Services. 

Certain financial-related information that we receive from or about Brightside’s individual users is covered under the Brightside Privacy Notice [add link].  If the Privacy Notice conflicts with the Privacy Policy because it is more restrictive, then the Privacy Notice controls to the extent of the conflict.

 

2. CHANGES TO THIS PRIVACY POLICY

The Effective Date of this Privacy Policy is set forth at the top of this page.  As we add new features to the Services, we may amend this Privacy Policy.  If we make a material change to this Privacy Policy that reduces your privacy rights, we will notify you at least 10 days in advance through the Services and/or by email so that you have time to stop using the Services before the amended Privacy Policy is in effect.  Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy.  The amended Privacy Policy supersedes all previous versions.

3. INFORMATION WE COLLECT

When you use the Services, we collect two types of information: Personal Information and Usage Data.   

In this Privacy Policy, “Personal Information” means any information that identifies or could be used to identify an individual. . Personal Information includes your contact data (name, telephone number and email address) and certain (but not all) Usage Data (defined below).  Information that does not identify an individual or cannot be used to identify an individual is not Personal Information,

We define “Usage Data” as information about an individual’s activity on or through the Services that, by itself, does not identify the individual, such as browser type, operating system and webpages visited.  Generally, we do not consider Usage Data as Personal Information because Usage Data by itself usually does not identify an individual.  Usage Data may, however, be Personal Information because it could be used to indirectly identify an individual.  When Usage Data can indirectly identify you, we treat it as Personal Information.

We may link Personal Information and Usage Data or different types of Usage Data.  We also may link publicly-available Personal Information, such as Personal Information available in public databases and through social networking websites. When the linked information identifies an individual person, we treat it as Personal Information.

 

4. HOW WE COLLECT INFORMATION

When you activate your account:  If you use the Brightside App, you will be required to register for an account.  When you register your account to use the Services, we collect name, email address, mobile number, last four (4) digits of your social security number and date of birth.  We use this information to validate your identity so that we can link the information that we collect from or about you with the information that  your employer provides to us.    By registering, you also authorize us to have access to data that your employer has shared with us so that we can serve you and understand your individual needs. 

When you use the Services: The information that we collect depends on how you use the Services.

When you use the Services, we collect information through our server logs.  A server log is a list of the activities that a server performs.  Brightside’s servers automatically collect and store information in server logs.

We may from time to time conduct surveys to better understand the needs and profiles of our users. You may choose whether to participate in any survey.  We collect the information that you provide in surveys.

We collect information about your computer, tablet or mobile telephone (“Device”), such as model, operating system version, mobile network information, IP address and MAC address, browser type, internet service provider, system settings, the country and time zone in which your Device is located, metadata and other information stored on your Device, as permitted by your operating system and account settings.  Brightside may associate your Device information with your Brightside account.  Some of this information is collected using Data Collection Technology as described in Section 5 below.

When you enable the location settings on your Device, we may collect your geolocation information with your consent.

We collect information that you send to us by text message. Once you opt-in to receive text messages from us, the frequency of text messages that we send to you depends on your transactions with us.  All charges are billed by and payable to your wireless service provider.  Please contact your wireless service provider for pricing plans and details.  Text message services are provided on an “as is” basis and may not be available in all areas at all times.

BY AGREEING TO RECEIVE TEXT MESSAGES, YOU UNDERSTAND AND AGREE THAT BRIGHTSIDE USES AN AUTOMATIC DIALING SYSTEM TO DELIVER TEXT MESSAGES TO YOU AND THAT YOUR CONSENT TO RECEIVE TEXT MESSAGES IS NOT REQUIRED AS A CONDITION OF PURCHASE FOR ANY GOODS OR SERVICES.

We also collect information that you share by telephone with a Brightside Assistant.

Through Partners: Brightside partners with other businesses, such as credit card debt and student loan refinancing providers, to provide certain resources for users.  When we have your consent, we collect information about you from or through our business partners to supplement the information that you provide to us. 

Through Service Providers: Third parties that assist us with our business operations also collect and process information through the Services and share that information with us.  For example, service providers collect information to help us detect and prevent fraud, conduct marketing campaigns, perform business and sales analysis, support the functionality of certain features of the Services and to help us administer surveys and issue product offerings and promotions.

Through Public Areas of the Services.  Brightside may offer areas in the Services where you can post information about yourself and others, communicate with others or upload content.  Whatever you post in a public area may appear on other websites or when searches are executed on the subject of your posting. Also, Personal Information you voluntarily disclose on publicly-viewable web pages can be collected and used by others. Brightside cannot control who has access to public information or what they may do with the information you voluntarily post, so we encourage you to exercise discretion when you publicly post your Personal Information.  (Please also see Section 5 of the Terms of Service for more information.)

Through Data Collection Technology: We and our service providers use cookies, pixel tabs (also known as web beacons, flash cookies and clear GIFs) and similar technology (“Data Collection Technology”) to automatically collect information about you when you use the Services.  Please read below to learn more about how Brightside uses Data Collection Technology. 

 

5. COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive.  A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services.  A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic.  To learn more about cookies and web beacons, visit www.allaboutcookies.org.

How We Use Data Collection Technology: Data Collection Technology helps us improve your experience of the Services by, for example, storing your password so you do not have to re-enter it each time you use the Services, measuring the success of marketing campaigns, compiling statistics about use of the Services and helping us analyze technical and navigational information about the Services and to detect and prevent fraud.

The Services use the following cookies:

  • Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to register or log in for the Services that we may offer.
  • Analytical/performance cookies, which allow us to recognize and count the number of visitors, to learn how visitors navigate the Services and to help us to improve the way Services function.
  • Functionality cookies, which are used to recognize you when you return to the Services.
  • Interaction cookies, which allow you to recommend us on Social Media

We also use Google Analytics which is a Google service that uses Data Collection Technology to collect information about use of the Services and report website trends.  This information, which Google may collect by tracking a user’s behavior across third-party websites, helps us to learn more about our users.  You can learn about Google’s practices in connection with this enhanced tracking and opt out of it by visiting www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

We also may use other Data Collection Technology to collect information from the Device that you use to access the Services, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located. 

Your Control of Cookies: Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your Device. You also may be able to reject mobile device identifiers by activating the appropriate setting on your Device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

Our Policy On Do Not Track Signals: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked.  If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain Personal Information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, many website operators, including Brightside, do not respond to DNT signals.

 

6. HOW WE PROCESS PERSONAL INFORMATION

Brightside processes Personal Information:

  • To set register your account with the Services;
  • To communicate with you;
  • To help you manage your account;
  • To prevent and investigate fraud and other misuses of the Services;
  • To protect our rights and property;
  • To operate, manage, secure and improve the Services;
  • To respond to your questions and to try to resolve problems with the Services;
  • To complete transactions requested by you; and
  • To help us improve our customer service.

Brightside processes Usage Data:

  • To analyze trends and gather broad aggregate demographic information;
  • To statistically monitor how many people are using the Services;
  • To develop, improve and protect the Services;
  • For audience research;
  • To audit and analyze the Services; and
  • To ensure the technical functionality and security of the Services.

 

7. HOW WE SHARE INFORMATION

Unless you consent, Brightside does not sell your Personal Information to or share your Personal Information with non-affiliated third parties for their own advertising or marketing purposes. But, Brightside may share Personal Information collected via the Services to help us provide the Services to you or to comply with law, as follows:

  • Service Providers: We share information with our third-party service providers that help us operate the Services, such as for conducting marketing campaigns, performing business and sales analysis and to helping us administer surveys, offers and other promotions. Brightside will ensure that any service provider with which we share Personal Information agrees to safeguard it in substantially the same manner as Brightside has described in this Privacy Policy and in accordance with all applicable laws. 
  • Corporate Transaction: We may share and transfer Personal Information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by Brightside or any affiliated company (in each case, whether in whole or in part).
  • When Required by Law: Applicable law may require Brightside to disclose your Personal Information if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant), government investigation or other legal requirements  or (ii) necessary for the prevention or detection of crime (subject in each case to applicable law).
  • Other Lawful Disclosures: We also share information if (i) disclosure would mitigate Brightside’s liability in an actual or threatened lawsuit; (ii) as necessary to protect legal rights of Brightside and its users, customers, business partners or other interested parties; (iii) to pursue available remedies or limit the damages; (iv) to enforce our agreements; and (v) to respond to an emergency.

Brightside may aggregate information collected though the Services and remove identifiers so that the information no longer identifies or can be used to identify an individual (“Anonymized Information”).  Brightside shares Anonymized Information with third parties and does not limit any third party’s use of the Anonymized Information.

Also, Personal Information you voluntarily disclose on publicly-viewable web pages can be collected and used by third parties that Brightside cannot control. Please use caution when you publicly post your Personal Information.

 

8. OPTING OUT OR CORRECTING INFORMATION

If you do not wish to receive marketing-related emails from us, please click the unsubscribe link in one of our marketing emails or email us at support@gobrightside.com.

You can cancel text messages at any time by texting "STOP". After you text "STOP", we may send you an additional text message to confirm that you are unsubscribed.  You will no longer receive text messages from that short code but you may receive text messages if you are subscribed to other text lists.  If at any time you have questions about the text messages, text "HELP". After you send "HELP" we will respond with instructions on how to use our service as well as how to unsubscribe.

You may at any time opt-out from allowing us to send you push notifications through the Brightside App by adjusting the permissions in your mobile device.

To correct Personal Information about you that you believe is incorrect, please email us at support@gobrightside.com.  Although we will try to do so, we may not be able to remove or correct your Personal Information in databases of third parties with which we have shared your information prior to your request.  Please contact those third parties directly.

Notice to California Residents: California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at support@gobrightside.com.

 

9.  LINKED SERVICES

The Services may include links to websites and services that are operated by our business partners or other third parties (“Linked Services”).  We try to connect you to Linked Services that are helpful to you but it is always your choice whether or not to engage with a Linked Service.  If you decide to use Linked Services, you hereby consent to such Linked Services disclosing to Brightside information regarding your use of the Linked Services (for example, if you apply for a loan through a third party loan provider, you consent to the third-party loan provider reporting to Brightside information whether you were approved for a loan, the loan amount and repayment information) in connection with the Services or to assist us in providing the Services to you. If you decide to visit a Linked Service, you are subject to its privacy policy, not ours.  We encourage you to read the privacy policy of each Linked Service that you visit or utilize.

 

10. PROTECTION OF PERSONAL INFORMATION

We take precautions intended to help protect information that we collect and store.   Unfortunately, however, no system or online transmission of data is completely secure. We cannot guarantee the security of information transmitted to or through the Services.  Any transmission is at your own risk and we expect that you will use appropriate security measures to protect your information. 

You are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password-protected or secure areas of the Services. Access to the Services through your user ID and password will be treated as authorized by you.  We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security.

If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below. 

 

11. CHILDREN’S PRIVACY

 

The Services are not directed to or intended for use by minors.  Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we have received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services.

 

12.  OTHER INFORMATION FOR YOU

If you have an account with us, you may close your account at any time by contacting us at support@gobrightside.com or calling +1-855-996-9750. Brightside may retain certain information associated with your account for analytical purposes and recordkeeping, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of the Services or our users or take other actions permitted by law. In addition, if certain information already was shared with third parties as described in this Privacy Policy, retention of that information will be subject to those third parties' data retention policies.

We are headquartered in the United States and the Services are controlled and operated from the United States.  The Services are intended for U.S. users. We process and store Personal Information in the United States, where privacy laws may not be as protective as in your place of residence.  If you are using the Services from outside of the United States, by providing your Personal Information to us, you consent to the transfer of your Personal Information to the United States for processing consistent with this Privacy Policy.

 

HOW TO CONTACT BRIGHTSIDE

Please contact us at support@gobrightside.com or by mail at Brightside Benefit, Inc., 3262 25th Street, San Francisco, CA 94110.