Brimby’s™ web application (the “WebApp”) follows all legal requirements to protect your privacy. This includes, without limitation, adherence to the General Data Protection Regulation (“GDPR”), which was enacted by the European Union (“EU”) to protect the fundamental right to privacy for every resident of the EU and became effective on May 25, 2018. The GDPR clarifies how personal data laws apply in the EU and may also be effective beyond the borders of the EU. Any company that works with EU resident’s data in any manner, regardless of location, is obligated to comply with the GDPR and Brimby™ takes any such obligations seriously.
Brimby™ collects Personal Information and Usage Data utilizing the following methods:
We may use your Personal information and share it with third parties:
Other than in connection with the limited use of Usage Data and Personal Information as specified above, Brimby™ shall never sell, rent, exchange or barter your Personal Information to or with any third party for financial gain or marketing purposes. When you register as a Member, your Personal Information that you make available is used to personalize your experience with the WebApp, facilitate the delivery of the applicable Brimby™ Offerings to you and for verification purposes. You also agree that we may contact you at any time with updates and any other information that we may deem appropriate for you to receive in connection with your continued use of the WebApp and Brimby™ Offerings, and to keep you informed of any additional products and services we may offer at any time in the future. In addition, if you identify yourself to us by sending us an email or some other communication with questions or comments, we may use such information (including Personal Information) to respond to your questions or comments, and we may file your questions or comments for future reference.
We may permit our third-party agents, Service Providers, vendors and subcontractors (such as vendors and suppliers that provide us with technology, services, advertising and marketing assistance or content in connection with our operation and maintenance of the WebApp and Brimby™ Offerings) to access Usage Data, but they are only permitted to do so in connection with performing services for us or to operate the WebApp and Brimby™ Offerings. Third parties are not authorized to use your Personal Information for their own benefit.
We may also supplement the information that we collect with information from other sources to assist us in evaluating and improving the WebApp and Brimby™ Offerings, and to determine your preferences so that we can tailor the WebApp and Brimby™ Offerings to your needs.
Information that we collect about you also may be combined by us with other information available to us through third parties for research and measurement purposes, including measuring the effectiveness of content or programs. This information from other sources may include age, gender, demographic, geographic, personal interests, product purchase activity, pages you visit or other information. We may report aggregate information, which is not able to be identified back to an individual Member of the WebApp, to research partners.
We reserve the right to release current or past Personal Information:
A cookie is a small piece of data that is sent to your browser from an email or a website's computers and stored in a browser-related file on your computer or other device. Cookies are uniquely assigned to your computer or device and are read by a web server in the domain that issued the cookie to you. We link cookies to your unique registration number and use them to enhance and personalize your experience on the Brimby™ Services, including helping authenticate you when you use the Brimby™ Services, remembering your preferences and registration information, and customizing the content provided to you. For example, storing a cookie on your computer or device allows you to login without typing the registered email address or registration number and password.
To support our Brimby™ Services, we may use one or more of the following cookies for the purposes indicated below:
Type of Cookie
Analytics and Performance Cookies
These Cookies are used to collect information about traffic to our Brimby™ Services and how often Members use our Brimby™ Services. The information gathered does identify any individual visitor. The information is aggregated and therefore anonymous. It includes the number of visitors to our Brimby™ Services, the websites that referred them to our Brimby™ Services, the pages that they visited, what time of day they visited our Brimby™ Services, whether they have visited our Brimby™ Services before, and other similar information. We use this information to help operate our Brimby™ Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Brimby™ Services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Brimby™ Services work.
These Cookies are essential to provide you with services available through our Brimby™ Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Brimby™ Services and help the content of the pages you request load quickly. Without these cookies, the Brimby™ Services that you have asked for cannot be provided, and we only use these Cookies to provide you with those Brimby™ Services.
These Cookies allow our Brimby™ Services to remember choices you make when you use our Brimby™ Services, such as remembering your language preferences, remembering your login details, and remembering the changes you make to other parts of our Brimby™ Services which you can customize. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Brimby™ Services.
We may also use “pixel tags,” which are small graphic files that allow us and third parties to monitor the use of the Brimby™ Services and collect Usage Data. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time (and length of time) the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any Cookie previously placed by that server on your computer.
We may use pixel tags, either provided by us or by our third party advertisers, Service Providers and ad networks, to collect information about your visit, including the pages you view, the links you click and other actions taken in connection with our sites and Brimby™ Services and use them in combination with our Cookies to provide offers and information of interest to you.
When you use the WebApp, or Brimby™ Offerings, including the Brimby™ Services, we may collect location information either provided by a mobile device interacting with our WebApp, or associated with your IP address, where we are permitted by law to process this information.
Brimby™ reserves the right to transfer aggregate or group data about Brimby™ Members (including Usage Data where such data is not linked to Personal Information) for lawful purposes. Aggregate or group data is data that describes the demographics, usage or other characteristics of Brimby™ Members as a group, without disclosing personally identifiable information.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
All of our Members’ Personal Information, not just the sensitive information mentioned above, is restricted in our offices. Only employees or third party agents who need the Personal Information to perform a specific job are granted access to Personal Information. Our employees are dedicated to ensuring the security and privacy of all Member Personal Information. Employees not adhering to our firm policies are subject to disciplinary action.<
Compromise of Information
In compliance with applicable federal and state laws or other laws applicable to persons using the Brimby™ Offerings in foreign countries, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your Personal Information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
At your written request, we will inform you of what Personal Information we have on file for you. You control your account information and settings: You may update your account information and email-communication preferences at any time by logging in to your account and changing your profile settings. You can also stop receiving promotional email communications from us by modifying your preferences at http://www.brimby.com.
However, we may maintain Personal Information whenever we are required to do so by law or regulations or as we believe is reasonably necessary to comply with applicable law or regulations, government requests, to detect or prevent fraud, to resolve disputes, to address problems with the Brimby™ Services, to assist with investigations, or to enforce our Terms and Conditions or other applicable agreements or policies. We may also need to retain certain information for recordkeeping purposes. We will retain your Personal Information for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
We make every effort to promptly process all unsubscribe requests. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Brimby™ Services, and technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at email@example.com.
Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Brimby™ Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Brimby™ Offerings-related and inquiry response-related messages from Brimby™, you must cease requesting and/or utilizing the Brimby™ Offerings and cease submitting inquiries to Brimby™, as applicable.
Opting out of collection of your information for Tracking:
Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable Cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling Cookies and/or other tracking tools prevents us from tracking your browser’s activities in relation to the Brimby™ Services. However, doing so may disable many of the features available through the Brimby™ Services. If you have any questions about opting out of the collection of Cookies and other tracking/recording tools, you can contact us directly at firstname.lastname@example.org.
How long we keep your private profile information:
Following termination of your Member account, we may retain your private profile information for a commercially reasonable time for backup, archival, or audit purposes. For the avoidance of doubt, any information that you choose to make public on the Brimby™ Services may not be removable.
We may use one or more third parties to provide specific services on our behalf, including sending emails to our Members, conducting Member surveys, processing transactions, providing all or a portion of an underlying product or Brimby™ Services on our behalf, or performing statistical analysis of the Brimby™ Services or data relating thereto. In these cases, we may provide your Personal Information to these Service Providers. However, these third parties are required to maintain the confidentiality of this information and are prohibited from retaining, sharing, storing or using this information for any other purposes.
As a Member, you will receive our customary business communications (e.g., emails, push notifications or other communications facilitating, completing or confirming your registration, upgrade or other transaction, providing you notice of new or updated products or features, or other administrative messages). We may also send certain "welcome" messages that are informational and provide useful details about your account or usage instructions when you sign up for an account or begin using a particular service. In addition, upon registration you may be automatically enrolled in one or more of our regularly recurring email subscription programs. You may also choose to participate in other email subscription programs that we may make available to you. We also may send you communications regarding special offers or other promotional material for our Brimby™ Services. We may send all of these communications to the primary email address that you provide to us or any secondary email address that you may have provided to us if we have determined that your primary email address appears to no longer be valid or otherwise functioning properly.
While we reserve the right to send you our customary business communications, "welcome" messages and other transactional emails without offering you the opportunity to opt out of receiving them, we do provide you with the opportunity to select whether or not you wish to continue to receive our subscription-based or commercial emails. Each subscription-based email communication from us contains instructions on how you can remove yourself from the mailing list for that specific email subscription program, and each commercial email contains instructions on how you can opt out of receiving further commercial emails from us.
You can also update your email preferences by logging onto the account or similar section of the Brimby™ Services.
Please keep in mind that any changes that you make to your email preferences may take up to ten (10) business days to process and that each subscription-based email and all commercial emails have their own separate opt-out processes. If you have questions about changing your email preferences, please contact the Customer Support team of the Service.
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not market or provide any services to children under 13. Minors (those under 13) are not eligible to use the Brimby™ Services, and we ask that minors not submit any Personal Information to us or use the Brimby™ Services. We will not knowingly collect information from minors or allow minors to become Members of our Brimby™ Services. If we later learn that a minor is a Member, then that minor's account will be terminated. We do not knowingly publish information concerning anyone under the age of 13. If you know of information appearing in the Brimby™ Services concerning anyone under the age of 13, please contact us.
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