B&P Ventures
Bright Digital Privacy Policy
We at Bright Digital and its affiliates (“Bright Digital” “us“, “we“, or “our“) recognize and respect the importance of maintaining the privacy of our customers. This Privacy Notice describes the types of information we collect from you when you visit our website (the “Site“) and/or use our services (“Services”). This Privacy Notice also explains how we may process, transfer, store and disclose the information collected by us or customers of our services (“Customers”), as well as your ability to control certain uses of the collected information. “You” means any adult user of the Site and/or Services or any parent or guardian of any minor whom you allow to use the Site and/or Services, and for whom you will be held strictly responsible, as well as any end-user of a Customer.
Bright Digital is joint data controller in respect of the processing activities outlined in this Privacy Notice related to your use of our Site and/or Services. Our registered office is 28 Haarba'a St., Tel Aviv, Israel, and our registration number 514951878. When we process information in the context of providing services to a Customer, the applicable Customer serves as a controller with respect to your data. . Additional entities who may be serving as separate, independent controllers are listed below.
“Personal Data” means any information that refers, is related to or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.
Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.
Personal Data We Collect. When you visit our Site or use our Services, we collect Personal Data provided by you, such as your name, email and home address, and telephone number. If you contact us for questions or complaints, we will collect the information related to your inquiry. We also (automatically) collect information about your use of the Site. We or our third parties also automatically collect your IP address, subject to your consent as may be required under applicable law, geolocation, Android ID/IDFA, and operating system.
How We Use the Information We Collect. We use the information (including Personal Data) we collect mainly to administer and provide the Site and/or Services, contact you with administrative information, provide you with our newsletter and/or contact you with marketing offers and/or promotional material, and improve the Site and Services.
The basis for Processing Your Personal Data. Processing your Personal Data is necessary for the provision of the Site and Services to you. Processing for the purposes of developing and enhancing features and our Services, for analytics and usage analysis, for provision of newsletters, promotional materials, and marketing offers, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
Sharing Personal Data We Collect. We may share the Personal Data we collect with our service providers and subcontractors who assist us in the operation of the Site and/or Services and process the information on our behalf and under our instructions as well as with our business partners, who act as independent separate controllers of the data . If you are an end-user of a Customer, we may also share Personal Data with such relevant Customers.
International Transfer. We may use service providers and/or subcontractors and/or cooperate with or have business partners and affiliates located in countries other than your own, and send them your Personal Data. We will ensure to have agreements in place with such parties ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
Your Rights. Subject to applicable law and additional rights as set forth below, you may have a right to access, update and/or delete your Personal Data and obtain a copy of the Personal Data we have collected about you. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes. You also have the right to object at any time to processing your personal data for marketing purposes.
Use of Cookies and Similar Technologies. We use cookies and similar technologies to help personalize your experience by helping save your settings and customizations across visits and providing you targeted content and advertisements. You can adjust your settings to determine which cookies you do or do not allow. Changing your settings and/or deleting existing cookies may affect your use of the Site.
Retention. We retain information for as long as necessary for the purposes set forth in this Privacy Notice.
Security. We implement industry-standard measures aimed at reducing the risks of damage and unauthorized access or use of Personal Data, but they do not provide absolute information security.
Changes to the Privacy Notice. We may change this Privacy Notice from time and shall notify you of such changes.
Information We Collect
We collect information from you when you choose to use our Site and/or Services. We also collect Personal Data when you request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason.
Examples of the Personal Data that we collect when you engage in such activities may include your name, IP address, phone number, and e-mail address.
In addition, when you use the Site or Services certain information may be automatically gathered about your computer or mobile devices, such as operating system, IP address, device ID, and subject to your consent as may be required under applicable law, (geo) location, as well as your browsing history and any information regarding your viewing on our Site.
If you are an end-user of a Customer, the Customer may also provide us with certain information automatically gathered about your computer or mobile device, such as your device language, operating system, platform, device ID, type of device, IP address, cellular operator and carrier, and subject to your consent as may be required under applicable law, (geo) location, as well as certain information with respect to your interaction with advertisements served to you.
It is your voluntary decision whether to provide us with any such Personal Data, but if you refuse to provide such information we may not be able to register you to the Site and/or provide you with the Services.
How We Use Your Personal Data
General
We and any of our trusted third-party subcontractors and service providers may use the Personal Data we collect from and about you for any of the following purposes: (1) to provide you with the Site and/or Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content and Services; (4) to contact you with informational newsletters and promotional materials relating to our Site and Services; (5) to provide you with customized content and advertising related to our products and Services; (6) to review the usage and operations of our Site and Services; (7) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (8) to prevent fraud, protect the security of our Site and Services, and address any problems with the Site and/or Services and (9) to provide customer support.
Statistical Information
By analyzing all information we receive, including all information concerning users, we may compile statistical information across a variety of platforms and users (“Statistical Information“). Statistical Information helps understand trends and customer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.
Analytics
We, or our service providers or subcontractors, may use analytics tools (“Tools“), including “Google Analytics” to collect information about the use of the Site and/or Services. Such Tools collect information such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. We use the information we get from the Tools to improve our Site and Services. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use
located at http://www.google.com/analytics/terms/us.html and the Google Privacy Policy located at http://www.google.com/policies/privacy/.
Legal Uses
We may use your Personal Data as required or permitted by any applicable law.
The basis for Processing Your Personal Data
Processing your Personal Data is necessary for the provision of the Site and Services to you, including responding to your inquiries or requests, contacting and communicating with you, and providing customer support.
Processing for the purposes of analytics and usage analysis, for fraud detection and prevention, for our recordkeeping and protection of our legal rights, compliance with legal and regulatory requirements, marketing of our services, network and information security, and product development and enhancements – are all necessary for the purposes of legitimate interests that we pursue.
Disclosure of Information
We may share your information, including Personal Data, as follows:
Business Partners, Service Providers, Affiliates, and Subcontractors
We may disclose information, including Personal Data we collect from and/or about you, to our trusted service providers, business partners, affiliates, subcontractors, who may use such information to: (1) help us provide you with the Site and/or Services; (2) help us contact you with informational newsletters and promotional materials relating to our Site and Services and ; (3) help us serve advertisements; (4) aid in their understanding of how users are using our Site and Services. If you are an end-user of a Customer, we may also share your Personal Data with such Customer.
Data Controllers
When you use our Site and/or Services, additional third parties, such as business partners may collect Personal Data about you and serve as separate, independent controllers with respect to the collection of your Personal Data. The details and contact information of such controllers are as set forth below.
Facebook Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, USA
Salesforce.com inc. Salesforce Tower 415 Mission Street, 3rd Floor San Francisco, CA 94105
International Transfer
We may use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own and send them the information we receive (including Personal Data). We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
Business Transfers
We may transfer our databases containing your Personal Data if we sell our business or part of it, including in cases of liquidation. Information about our users, including Personal Data, may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition and shall continue being subject to the provisions of this Privacy Notice.
Law Enforcement Related Disclosure
We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior, or (digital) content and information of or related to an individual, including in the event of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of this Privacy Notice); (ii) to protect the rights, property or safety of third parties; (iii) when required by law, regulation subpoena, court order or other law enforcement related issues; or (iv) as is necessary to comply with any legal and/or regulatory obligation. You can request such Personal Data as specified herein by emailing us at info@brtdigi.com.
How We Use Your Personal Data
We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it, including by implementing the below:
Safeguards – The physical, electronic, and procedural safeguards we employ to protect your data include secure servers, firewalls, antivirus and SSL encryption of data.
Access Control – We dedicate efforts for proper management of system entries and limit access only to authorized personnel on a need to know on the basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination.
Internal Policies – We maintain and regularly review and update our privacy-related and information security policies.
Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practices.
Database Backup – Our databases are backed up on a periodic basis for certain data and which are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity and are tested regularly to ensure availability, and are accessed only by authorized personnel.
However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
How to Access and Limit Our Use of Certain Information
You have certain rights in relation to the Personal Data that we or other controllers hold about you, as detailed below. For any requests to exercise such rights with respect to information held by other controllers, please contact the applicable controller directly. If you wish for us to notify all independent controllers, please specify that request when you contact us in order to exercise any of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
Right of Access and Data Portability. You have a right to know what Personal Data we collect about you and, in some cases, to have the information communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Data you provided to us (excluding information that we obtained from other sources) in a structured, commonly used, and machine-readable format, and you may have the right to (request that we) transmit such Personal Data to another party. If you wish to exercise this right please contact us letting us know what information, in particular, you would like to receive and/or transmit. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, for instance, if the information includes Personal Data about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Data and/or that we suspend the use of Personal Data, the accuracy of which you may contest, while we verify the status of that Personal Data. We will correct your Personal Data within a reasonable time from the receipt of your written request thereof.
Deletion of Personal Data (“Right to be Forgotten”). In certain circumstances, you have a right to have Personal Data that we hold about you deleted. Should you wish to have any Personal Data about you deleted, please contact us, using the contact information specified in this Privacy Notice. Subject to applicable law, we will delete Personal Data provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected Personal Data. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should clear our cookies from any device where you have visited our Site. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, as well as other purposes, all as permissible and/or required under applicable law. We may also retain your information in an anonymized form.
Direct Marketing Opt-Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes. If you do, please notify us by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however, it may take a few days for us to update our records before any opt-out is effective. Right to Object. Subject to applicable law, you may have the right to object to the processing of your Personal Data for certain purposes
Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.
Retention Data
Subject to applicable law, we retain information as necessary for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth in this Privacy Notice.
Cookies and Similar Technologies
What are Cookies?
A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this visitor returns.
A “session cookie” is temporary and will remain on your device until you leave the Site.
A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device for much longer or until you delete it.
First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
Information may also be collected through web beacons, which are small graphic images (“pixel tags”), which usually work together with cookies in order to identify users and user behavior. These may be shared with third parties.
We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.
How We Use Cookies
We use cookies and similar technologies for a number of reasons, for example, in order to help personalize your experience. and to personalize the ads we serve you. Third parties through which we provide the Services and/or our business partners may be placing and reading cookies on your browser or using web beacons to collect information in the course of advertising being served on different websites.
The specific names and types of cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:
Type of Cookie
Necessary
Functionality
Security
Performance
Analytics
Advertising
Why We Use These Cookies
These cookies are necessary in order to allow the Site to work correctly. They enable you to access the Site, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.
These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.
These cookies can help us identify and prevent security risks. They may be used to store your session information.
These cookies can help us collect information to help us understand how you use our Site, such as whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Site.
These cookies help us learn more about which features are popular with our users and how our Site can be improved.
These cookies are placed in order to deliver content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This can help us track how efficient advertising campaigns are for our own Services. Such cookies may track your browsing habits and activity when visiting our Site and those of third-parties.
How to Adjust Your Preferences
Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Site may function improperly when cookies are disabled or removed.
By changing your device settings, you can prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier. Typically, you can find the ad identifier settings under “privacy” or “ads” in your device’s settings, although settings may vary from device to device. Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements, it only means the advertisements that you do see will be less relevant to your interests.
Third-Party Cookies
Google Analytics – Analytics cookie
Hubspot – Functionality cookie
Salesforce – Functionality cookie
Facebook – Functionality cookie
Google Adwords – Functionality cookie
Mailchimp – Functionality cookie
Constant Contact – Functionality cookie
Facebook – Advertising cookie
Google – Advertising cookie
Third-Party Applications and Services
Portions of the Site may involve linking to or using web applications or services belonging to third parties. Nonetheless, all use of third-party applications or services is at your own risk and subject to such third party’s privacy policies.
Communications
Subject to your consent as may be required under applicable law, we may send you e-mail or other messages and/or a newsletter about us or our Services. You may remove your Personal Data from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at info@brtdigi.com. You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send. Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt-out of receiving them. Should you not wish to receive such communications you may cancel your account.
Children
We do not knowingly collect personally identifiable information from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.
Changes
If you do not agree with the terms hereof, please do not use the Site and/or Services. We may update this Privacy Notice from time to time –we encourage to review it periodically. By continuing to access or use the Site and/or Services after those changes become effective, you agree to be bound by the revised Privacy Notice. We will post the updated Privacy Notice on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new Privacy Notice will be effective from the date it is accepted by you.
Comments and Questions
If you have any comments or questions about our privacy policy, or if you wish for us to amend or delete your Personal Data, please contact us at info@bnpventures.com
Last updated: July , 2020