PRIVACY POLICY
We know that no one likes to read such long texts, but here is all the information about how we work with your data. Because data is the most valuable asset in the age of information technology and bitcoins.
1. In this policy, the following terms shall have the following meanings
1.1. “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
1.2. “Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
1.3. “We/Us/Our” means Brightgrove, a company focused on software development, consulting and outsourcing.
2. What does this policy cover
2.1. This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
3. Your rights
3.1. As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
3.1.1. The right to be informed about Our collection and use of personal data;
3.1.2. The right of access to the personal data We hold about you;
3.1.3. The right to rectification if any personal data We hold about you is inaccurate or incomplete;
3.1.4. The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time);
3.1.5. The right to restrict (i.e. prevent) the processing of your personal data;
3.1.6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organization);
3.1.7. The right to object to Us using your personal data for particular purposes;
3.1.8. Rights with respect to automated decision making and profiling.
3.2. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 11 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office.
3.3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
4. What do we collect
Depending upon your use of Our Site, We may collect some or all of the following personal data (please also see section 12):
4.1. [name];
4.2. [contact information such as email addresses and telephone numbers];
4.3. [web browser type and version];
4.4. [operating system];
4.5. [ a list of devices and their screen resolutions].
5. How do we use your data
5.1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under GDPR at all times. For more details on security see section 7, below.
5.2. Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
5.2.1. Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
5.2.2. Replying to emails from you;
5.2.3. Supplying you with emails that you have opted into (you may unsubscribe any time);
5.2.4. Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
5.3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and telephone with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
5.4. Third parties (Google analytics, Facebook analytics, Linkedin analytics, Twitter analytics, Google Tag Manager) whose analytical tools are implemented on Our Site, may use third party Cookies, as detailed below in section 12. Please refer to section 12 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
5.5. You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
5.6. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for shortest period (it depends on third-party services).
6. How do we store your data
6.1. We only keep your personal data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.
6.2. 6.2. Your data may be stored in Germany, Ukraine, Poland, Romania or United States of America.
7. How do we share your data
7.1. Unless otherwise is provided in this Policy, We will not share any of your data with any third parties for any purposes.
7.2. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
7.3. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymized and will not include any personally identifying data, or any anonymized data that can be combined with other data and used to identify you.
7.4. We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR.
8. What happens if our business changes hands?
8.1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
8.2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. How can you control your data?
9.1. In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
10. Your right to withhold information
10.1. You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
10.2. You may restrict Our use of Cookies. For more information, see section 12.
11. How can you access your data?
11.1. You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at data.protection@brightgrove.com.
12. Cookies policy
12.1. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
12.2. By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site. For more details, please refer to section 12.3 below.
12.3. All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:
12.3.1. Strictly Necessary Cookies
A Cookie falls into this category if it is essential to the operation of Our Site. These cookies are necessary to allow us to operate our Site so you may access them as requested.
These also include cookies, which allow us to remember your previous actions within the same browsing session, and to secure the Site.
12.3.2. Analytics Cookies
It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.
12.3.3. Functionality Cookies
Functionality Cookies enable Us to provide additional functions to you on Our Site such as personalization and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
12.3.4. Targeting Cookies
It is important for Us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you. We never share this information with third parties for any purposes.
12.3.5. Third Party Cookies
Third party Cookies are not placed by Us; instead, they are placed by third parties that provide services to Us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on Our Site, or by third parties providing analytics services to Us (these Cookies will work in the same way as analytics Cookies described above).
12.3.6. Persistent Cookies
Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.
12.3.7. Session Cookies
Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.
12.3.8. Cookies on Our Site are not permanent and will expire after a year of using. Afterwards their using re-launch automatically.
12.3.9. For more specific details of the Cookies that We use, please refer to the table below.
Contacting us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at data.protection@brightgrove.com. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.
Changes to our privacy policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.