Your privacy is very important to us. At Brinn Marketing we have a few fundamental principles that we follow:
Effective November 17, 2022
SCOPE OF POLICY
- Clients – individuals who purchase or otherwise use our Services.
- Event/Marketing Participants – individuals who provide their information to us when they register for our webinars, subscribe to marketing material, participate in surveys or contests, or attend our other events.
- Website Visitors – individuals who visit our Website, including those who opt to provide contact information to receive communications from us.
INFORMATION WE COLLECT
Clients – We ask for your information, which may include your name, email address, physical address, phone number, credit card information, and website domain, to enable us to create an account for you and provide you our Services. By providing us with this information, you represent that you own and consent to our use of such personal information. When you and your end users use our Services, we may automatically collect information about how and where the Services are used, including but not limited to geolocation data, versioning, site health information, configuration settings, and reporting (collectively, “Usage Data”). You may opt out of collection of Usage Data at any time by changing the settings in your account. You understand that this Usage Data may include limited personal information, and therefore you represent and warrant that if you opt in to the collection of this Usage Data, you have made all necessary disclosures to and obtained all necessary consents from your end users for the collection of Usage Data.
Event/Marketing Participants – We may ask for your name, email address, physical address, and phone number to enable you to participate in events, surveys, contents, or to subscribe to marketing materials. Such participation is voluntary and you may choose whether or not to participate and therefore disclose this personal information.
HOW WE USE YOUR INFORMATION
We use the information we collect about you in the following ways:
- To respond to any requests from you, including those regarding sales and support.
- To contact you regarding any agreements or accepted terms that you may have with us for the Services.
- To provide you with marketing emails, special offers, advertising campaigns, or newsletters.
- To understand how our Services and Website are used.
- To provide you with information logs associated with the use of our Services.
- To contact you regarding functionality changes to our Services or Website.
- To improve our offerings, including developing new features and functionality for our Services and Website.
- To collect payment and bill for our Services.
- To help personalize searches.
- To diagnose and troubleshoot problems.
- To find and prevent fraud.
- To register your domain and IP address through ARIN (American Registry for Internet Numbers).
- To carry out other purposes as disclosed to you through the Website, or found in terms or an agreement between us and you.
- To process the information for other purposes for which we obtain your consent.
HOW WE SHARE INFORMATION
We share the information we collect about you in the following ways:
Advertising – Based on cookies and other tracking devices, we may work with advertising companies to display ads that may be of interest to you.
Business Transactions – To provide information to a third party in the event of any disposition of all or any portion of our business (e.g. reorganization, sale, assignment, bankruptcy).
To Create De-identified Data – We may aggregate or otherwise de-identify your personal information so that it is no longer able to be associated with you (“De-identified Data”). We own all De-identified Data and may use and share this information with third parties.
As Required by Law or Similar Investigations – To comply with legal obligations (e.g. subpoena) or investigate potential legal violations. We may be required to share personal information in response to lawful requests from public authorities including to meet national security and/or law enforcement requirements.
Safety – We may disclose your information to protect and defend our safety and those of other users in connection with investigating and preventing fraud or security issues.
Consent – We may share your information for other ways not described above with your consent.
You may opt-out of the collection of Usage Data by logging into your account and changing your collection settings or contacting us as detailed at the end of this Policy. You may unsubscribe from receiving promotional or marketing emails from us at any time by using the “unsubscribe” link in the email received, or by emailing us as detailed at the end of this Policy. As outlined above, you can also control your cookie settings.
With respect to your account information, you may update, correct or delete information that you provided to us by logging into your account or contacting us as detailed at the end of this Policy.
You are not required to provide all personal information identified in this Policy to use our Website or receive our Services, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.
DATA RETENTION AND SECURITY
When we no longer have a legitimate business need (e.g. termination of a Client agreement) to process your personal information, we will either delete or de-identify it.
We take all reasonable steps to protect information we receive from you from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We maintain technical, physical, and administrative safeguards to secure your information, and we use industry standard encryption for your data that is transferred over the internet. Despite our use of encryption, we cannot guarantee any method of transmission of information over the internet is 100% secure. If you have any questions about the security of your personal information, please contact us as detailed at the end of this Policy.
We are a US company and store your information in our data centers in the United States. We may transfer your personal information to countries other than the country in which you live. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.
Our Website and Services are not directed at children. We do not knowingly collect personal information from or about children under 13 years of age, and purchase of our Services by children under 13 years of age is forbidden.
THIRD PARTY SITES AND SERVICES
The Website may contain links to other websites and services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and we are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and sharing of your personal information. We encourage you to read their privacy policies to learn more.
NOTICE TO EUROPEAN USERS
The following applies to individuals in the European Economic Area (EEA) and United Kingdom (UK):
|Processing Purpose||Legal Basis|
|To provide the Website and our Services and communicate with you.||You are subject to a contract with us and we need to use your personal information to provide services you have requested or take steps that you request prior to providing services.|
|To analyze our Service usage, improve our Services, and send you marketing communications.|
For compliance, fraud prevention, and safety.
|These processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|For compliance with law.||Processing is necessary to comply with our legal obligations.|
|With your consent.||If we expressly ask for your consent prior to processing your information, our processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated on the Website.|
|To share your personal information as described in this Policy.||This sharing constitutes our legitimate interests, and in some cases may be necessary to comply with our legal obligations.|
Retention – We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights – EEA and UK data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
Cross-Border Data Transfers – Any information you provide to us through the use of the Website may be stored, processed, transferred among, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Policy regardless of where your personal information is kept. Regarding transfers from the EEA and UK to the United States, we rely on the derogations for transfers which are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. If you reside in other non-US jurisdictions outside the EEA and UK, your use of the Website or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified above. If you have questions about cross-border transfers, please contact us as detailed below.
NOTICE TO CALIFORNIA RESIDENTS
The following section applies to California residents.
The California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CPRA”) creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CPRA, both our privacy practices and your privacy rights are discussed in detail in the following information.
|Category of Personal Information Collected||Business Purpose of Collection||Source(s) of information|
|Identifiers, including real name, alias, mailing address, email address, account name, telephone numbers, and unique personal identifiers such as online identifiers and IP address||To provide our Website and Services and to market our Services to you||Directly from you when you contact us, order Services, set up an account, or respond to promotions as well as through our authorized resellers if you purchase Services through them, and passively when you visit our Website or use our Services|
|Geolocation data||To provide our Services and assist in marketing and identify Website traffic patterns||Passively when you visit our Website or use our Services|
|Financial information, including credit card number or debit card number||To fulfill your orders for our Services||Directly from you or from our authorized resellers when you pay for Services|
|Commercial information, including Services purchased||To fulfill your orders for our Services||Directly from you or from our authorized resellers when you order our Services|
|Internet or other electronic network activity information, including browsing history, search history, and information regarding an individual’s interaction with an internet site, application, or advertisement||To provide you more relevant content, track original Website visits, and optimize your Website experience as well as to ensure our systems are properly functioning||Passively when you visit our Website or use our Services|
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice. We will only retain your information as long as it is reasonably necessary for the purposes for which it was collected.
Sharing Your Information – We do not share your personal information with third parties for cross-context behavioral advertising purposes or otherwise sell your personal information, but we may disclose your personal information to third parties for a business purpose. Specifically, in the past 12 months we have disclosed unique personal identifiers such as online identifiers and IP address and Internet or other electronic network activity information to our internet service providers, operating systems and platforms, and marketing intelligence service providers.
Your Rights – California residents have certain rights regarding your personal information:
- Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
- Right to Correct. You may request that we correct inaccurate personal information we maintain about you.
- Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.
- Shine the Light. Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes.
Exercising Your Rights – To exercise your rights above, please submit a request to us by emailing us at email@example.com, or by calling us at 1(800) 284-4926. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide the following information: name, email address, and the type of request you wish to make. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request. After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request. Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. We may not discriminate against you if you choose to exercise your rights.
Responding to Your Rights Request – We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. We will deliver our written response by mail or electronically. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable. We will not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.
c/o Brinn Marketing, LLC
Attn: Marketing Director
1228 Jamestowne Drive
Elon, NC 27244
What are Cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies set by the website are called “first party cookies.” Cookies set by parties other than the website owner are called “third party cookies.” Third party cookies enable third party features or functionality, such as advertising or website analytics, to be provided on or through the website. The parties that set these third party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites and/or mobile apps.
What Cookies and Other Tracking Technologies does this Website User? We may use several different kinds of cookies on this Website, including strictly necessary cookies, which are cookies that are necessary for the Website to function and cannot be switched off in our systems; performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our Website; and third party cookies.
Cookies are not the only way to track visitors to a website. We may use similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Websites. These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning.
How Can You Disable Cookies and Other Tracking Technology? Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com. Some Internet browsers also may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.