3. INFORMATION WE COLLECT
When you use the Services, we collect two types of information: Personal Information and Usage Data.
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.)
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:
- 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 firstname.lastname@example.org.
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 email@example.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 firstname.lastname@example.org.
9. LINKED SERVICES
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
HOW TO CONTACT BRIGHTSIDE
Please contact us at email@example.com or by mail at Brightside Benefit, Inc., 3262 25th Street, San Francisco, CA 94110.