Privacy Policy

September 28, 2019

At Brinn Marketing, LLC we recognize that privacy is important. This Policy applies to all of the products, services and websites offered by Brinn MArketing, LLC or its subsidiaries or affiliated companies (collectively, Brinn Marketing’s “services”). In addition, where more detailed information is needed to explain our privacy practices, we post separate privacy notices to describe how particular services process personal information. By using the Brinn Marketing websites, products, services, mobile apps (“app(s)”), and applications (collectively, “Services”), you agree to the Brinn Marketing Privacy Policy

IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE THE SERVICES

Information we collect and how we use it:We offer a number of services that do not require you to register for an account or provide any Personal Information to us. “Personal Information” is information that can be used to identify, locate, or contact an individual. It also includes other information that may be associated with Personal Information. “Non-Personal Information” is information that, alone, cannot be used to identify or contact you. Such Non-Personal Information may include, for example, gender, birthdate, or zip code. You may be asked to submit Non-Personal Information with Personal information, or separately.

In order to provide our full range of services, we may collect the following types of information:

  • Information you provide – When you sign up for a Brinn Marketing Account or other Brinn Marketing service or promotion that requires registration, we ask you for Personal Information (such as your name, email address and an account password). For certain services we also request credit card or other payment account information which we maintain in encrypted form on secure servers. We may combine the information you submit under your account with information from other Brinn Marketing services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information. If you use a social media platform or your mobile device (or other method of communication) to interact with Brinn Marketing, the communication method or application may have a specific privacy policy that governs the use of Personal Information.
  • Brinn Marketing cookies and related technologies – When you visit Brinn Marketing, we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. We use cookies and related technology to improve the quality of our service by storing user preferences and tracking user trends. You may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set by us. However, some Brinn Marketing features and services may not function properly if your cookies are disabled.
  • User communications – When you send email or other communication to Brinn Marketing, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
  • Log information – When you use Brinn Marketing services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
  • Affiliated sites – We offer some of our services in connection with other web sites. Personal information that you provide to those sites may be sent to Brinn Marketing in order to deliver the service. We process such information in accordance with this Policy. The affiliated sites may have different privacy practices and we encourage you to read their privacy policies.
  • Links – Brinn Marketing may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our search technology, customized content and advertising. For more information about links and redirected URLs, please see our FAQs.
  • Other sites – This Privacy Policy applies to web sites and services that are owned and operated by Brinn Marketing. We do not exercise control over the sites displayed as search results or links from within our various services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

Brinn Marketing only processes Personal and Non-Personal information for the purposes described in the applicable Privacy Policy and/or privacy notice for specific services. In addition to the above, such purposes include:

  • Providing our products and services to users, including the display of customized content and advertising;
  • Auditing, research and analysis in order to maintain, protect and improve our services;
  • Ensuring the technical functioning of our network;
  • Developing new services.
  • Facilitate orders for products or services;
  • Evaluate eligibility of customers for certain offers, products, or services;
  • Track redemption of products or services and perform other analytics;
  • Provide customer support, including support to our merchants or business partners;
  • Fulfill requests for Brinn Marketing products or services;
  • Communicate and provide additional information that may be of interest to you about Brinn Marketing Tools, our merchants, and our business partners, such as news, special offers and coupons, announcements, and marketing materials;
  • Send you reminders, technical notices, updates, security alerts and support, and administrative messages, service bulletins, or marketing materials;
  • Manage our everyday business needs, such as website administration, fulfillment, analytics, fraud prevention, compliance with the law, or enforcement of our corporate reporting obligations, terms, and conditions; and
  • Aggregate anonymous data from our services, used to benchmark, to improve the Services, and to provide data analysis.

You can find more information about how we process Personal and Non-Personal information by referring to the privacy notices for particular services.

Brinn Marketing processes Personal Information on our servers in the United States of America and in other countries. In some cases, we process Personal Information on a server outside your own country. We may process Personal Information to provide our own services. In some cases, we may process Personal Information on behalf of and according to the instructions of a third party, such as our advertising partners.

Choices for personal information:When you sign up for a particular service that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.

If we propose to use personal information for any purposes other than those described in this Policy and/or in the specific service notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Policy and/or in the specific service notices, unless we have obtained your prior consent.

You can decline to submit personal information to any of our services, in which case Brinn Marketing may not be able to provide those services to you.

Information sharing:Brinn Marketing will not disclose your Personal Information to third parties except to our service providers. We do NOT share, sell, rent, or trade Personal Information with third parties for their own promotional purposes. Brinn Marketing shares your Personal Information in the following limited circumstances:

  • We have your consent. We require opt-in consent for the sharing of any Personal Information.
  • We provide such information to third party service providers for the purpose of processing Personal Information on our behalf. Our service providers are bound by law or contract to protect the Personal Information and are only allowed to use the Personal Information in accordance with the terms of our service agreements with them.
  • We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of Brinn Marketing, its users or the public as required or permitted by law.

If Brinn Marketing becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

Brinn Marketing may aggregate information collected by the Services or via other means so that the information does not identify you. Our use and disclosure of anonymous, aggregated information, and other Non-Personal Information, is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any legal purpose.

Please contact us at the address below for any additional questions about the management or use of personal data.

Information security:We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to Personal Information to Brinn Marketing employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Data integrity:Brinn Marketing processes Personal Information only for the purposes for which it was collected and in accordance with this Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the Personal Information needed to provide or improve our services. We take reasonable steps to ensure that the Personal Information we process is accurate, complete, and current, but we depend on our users to update or correct their Personal Information whenever necessary.

Accessing and updating personal information:When you use Brinn Marketing services, we make good faith efforts to provide you with access to your Personal Information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. Please contact us at the address below to request access or correction of your Personal Information. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Some of our services have different procedures to access, correct or delete users’ personal information. We provide the details for these procedures in the specific privacy notices or FAQs for these services. We will retain your information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

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