PRIVACY POLICY

This Privacy Policy explains how we collect, use and disclose personal information about you. This Privacy Policy applies to Bright Talent and Bright Experience ("Bright," "we," “our” or "us").

This Privacy Policy applies when you access or use our websites or mobile applications that link to this Privacy Policy, contact our customer service teams, or otherwise interact with us (collectively, the “Services”). This Privacy Policy does not apply to any Services or other websites that display or reference a different Privacy Policy.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. In some cases, we may provide you with additional notice (such as a statement on our website). Please review this Privacy Policy from time to time so you understand our privacy practices and your choices regarding how we use your personal information.

1. INFORMATION WE COLLECT

Information You Provide to Us
We collect information directly from you. For example, we collect information when you sign up or register to use our services. We collect information when you sign up to receive notifications or other communications from us. We also collect information when you request customer support; engage with us on social media; fill out a form; or participate in a survey or promotion. The types of information we collect directly from you may include:

Identification information, such as your name, title, date of birth, identity document (e.g., driver’s license, passport or tax identification number). Contact information, such as your mailing address, email address, and phone number.  Demographic information, such as your age and gender. Payment information, including your payment card information and billing address. Information necessary for us to provide Services.

Information We Collect Automatically
We automatically collect information about you when you access or use our Services or do business with us. For example, we collect:

Browsing and Usage Information. When you use our internet-based Services, some information is collected automatically, including as described in the Cookies and Similar Technologies section below. For example, when you visit our websites, our web servers automatically log your computer's operating system, Internet Protocol (IP) address, access times, browser type and language, the website you visited before our site, and your activity on our websites. We also collect information about what products and services you browse or express an interest in and we track your activity on our Services and websites where our advertising is served, such as which pages and ads you view or click on.

Device Information. We collect information about the computer or mobile device you use to access our Services. This may include the hardware model, operating system and version, unique device identifiers, and mobile network information.

Location Information. We may collect or infer information about your general location when you access or use the Services or turn on Bluetooth, Wi-Fi or other geolocation functionality on your device. If you enable location services on your device, we collect more precise geolocation information. This lets us to notify you of products and services available in your area, and provide location-based services or functions. You can opt-out of the collection of precise geolocation information at any time (see Your Choices below for details).

Call Recordings and Chat Transcripts. We record and store telephone calls and chat transcripts for a period of time when you interact with our customer or technical support personnel.

Information We Create or Generate
We infer new information from the information we collect, including using automated means to create or generate information about your likely preferences, interests, or other characteristics (“inferences”). For example, we may infer your city, state, and country location based on your IP address or zip code. We may also infer products or services that may interest you based on your prior purchases with us, our vendors, or other companies you engage with.

Information We Receive from Other Sources
We may collect information about you from other sources that we may combine or link with information we have about you. We may combine information that we have collected offline with information we collect online.

2. USE OF INFORMATION
We use the information we collect about you to help us operate our business. In particular, we use the information we collect (as described in Section 1 above) for the following purposes:

Product and Service Delivery. To provide our products and services, including securing, troubleshooting, improving, and personalizing those products and services.

Business Operations. To operate our business, such as: creating, maintaining, and renewing services; billing, accounting, improving our internal operations; securing our systems, and detecting fraudulent or illegal activity; monitoring and analyzing trends, usage and activities in connection with our Services; and for any other business purpose permitted by law: All categories described in Section 1 above.

Product Improvement, Development, and Research. To improve our products, develop new products or features, and conduct research: All categories described in Section 1 above.

Personalization. To understand you and your preferences to enhance your experience and enjoyment using our services and personalize your online experience and the advertisements you see when you use the Services or other platforms: identification information, contact information, demographic information, browsing and usage information, device information, location information, inferences, and data sourced from other companies.

Customer Support. To provide customer support and respond to your questions and warranties: identification information, contact information, location information, call recording and chat data, and data sourced from other companies.

Communications. To send you information and notices about your account such as updates, security alerts, and support and administrative messages: identification information, contact information, browsing and usage information, device information, and location information.

Marketing. To communicate with you about new services, offers, promotions, contests, upcoming events, and other information about our services and those of other selected companies: Identification information, contact information, location information, inferences, and data sourced from other companies.

Advertising. To display advertising to you (see the Cookies section of this privacy statement for information about personalized advertising and your advertising choices): identification information, contact information, aggregated demographic information, browsing and usage information, device information, location information, inferences, and data sourced from other companies.

Legal, Security, and Safety Reasons. This may include protecting our rights and the rights of our customers, communicating, detecting, investigating, or preventing fraud and other illegal activities, and addressing legal and regulatory compliance obligations, or verifying your identity in connection with requests made under this Privacy Policy: All categories described in Section 1 above.

For any other purpose described to you at the time information is collected: All categories described in Section 1 above.

In carrying out these purposes, we combine data we collect from different sources to give you a more seamless, consistent, and personalized experience.

We do not direct the Services to individuals under the age of eighteen (18). We do not knowingly collect Personal Information from individuals under 18 except as provided to us.

3. SHARING OF INFORMATION
We share information as described in this Privacy Policy.

Vendors, Service Providers and Consultants. We share information with our vendors and service providers that help us run our business. For example, we share contact information and transaction information with companies that help us:
provide customer service and resolve complaints;
identify, investigate and prevent fraudulent transactions;
analyze data or member activity;
design and execute our marketing campaigns, administer our promotions, and provide advertising services; Corporate Transactions. We may disclose information about you as part of a corporate transaction. This could be a merger, acquisition, joint venture, sale of company assets, reorganization, divestiture, bankruptcy or similar type of business transaction.

Legally Required Disclosures, Other Uses and Disclosures. We share information about you as necessary to comply with applicable law or legal process, such as requests from authorities, regulators and courts. We share information to respond to complaints or legal claims or to protect the rights, property or personal safety of our customers, consultants, employees or the public. We may also share aggregated or de-identified information that cannot reasonably be linked to you.

4. COOKIES AND SIMILAR TECHNOLOGIES
We use cookies, web beacons, and similar technologies to operate our websites and online services and to help collect data.

Cookies are small text files placed on your device to store data that can be recalled by a web server in the same domain that placed the cookie. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well.

We use cookies on our websites to store your preferences and settings, enable you to sign-in, provide interest-based advertising, combat fraud, and fulfill other legitimate purposes.

Our web pages may also contain electronic images known as web beacons (also called pixel tags or clear gifs) that we use to count users who have visited those websites, and gather usage and performance data. We also include web beacons in our promotional email messages or newsletters to determine whether you open and act on them.

Our websites may include web beacons and cookies from our service providers, such as site analytics. In other cases, it is because our web pages contain content or ads from other companies, such as videos, news content, or ads delivered by other ad networks (see Advertising, Services Provided by Others; Interest-Based Advertising below). Because your browser connects to web servers operated by other companies to retrieve that content, those other companies are able to set or read their own cookies on your device and may collect information about your online activities across websites or online services.

The analytics providers we use include the following:
Adobe Advertising, analytics | https://www.adobe.com/privacy/policy.html | https://www.adobe.com/privacy/opt-out.html

Google Analytics, analytics | https://policies.google.com/technologies/partner-sites | https://tools.google.com/dlpage/gaoptout

Squarespace, analytics | https://www.squarespace.com/privacy

LiveAgent | https://www.liveagent.com/privacy-policy

To opt-out from the collection or use of Adobe, Google, Squarespace, and LiveAgent analytics data, and to learn more about their privacy practices, click on the links above. You can also opt-out of targeting cookies on our website by opting out in our cookie settings tool. You can use browser controls to limit how the websites you visit are able to use cookies. Instructions for blocking or deleting cookies may be available in each browser's privacy or help documentation. Please be aware that if you choose to block cookies, certain website features that depend on cookies may no longer function. Choices you make regarding cookies are specific to your browser and device. If you choose to delete cookies, settings and preferences controlled by those cookies, including your opt-out and advertising preferences, may be deleted and may need to be recreated.

Mobile Advertising ID Controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.

5. OTHER SITES; SOCIAL MEDIA AND SOCIAL SHARING FEATURES
The Services may offer social sharing features that let you share information on your social media accounts such as through the Facebook “Like” button. When you use these features, you are sharing information with your friends or the public, depending on your social media account privacy settings. For information about data collection and use in connection with social sharing features, please read the privacy policies of the companies that provide these features. Any information you post or disclose on message boards, chat, profile pages, blogs and other services, including our Social Media Pages, may be public and viewable by other users. The use of shared information is governed by the social media provider’s privacy policy.

6. ADVERTISING SERVICES PROVIDED BY OTHERS; INTEREST-BASED ADVERTISING
We engage analytics and advertising companies to collect information when you visit our website or use our mobile applications. We and these companies may collect information from cookies, pixel tags, device identifiers, and other technologies about your browsing activity and use of the Services, websites, and apps (see Cookies and Similar Technologies for more information). We and our vendors may use this information to serve advertisements on our behalf or deliver advertising and content targeted to your interests.

Interest-Based Advertising. Some of these companies deliver advertising and content based on your activity across websites and over time. This is interest-based advertising.

Opting Out. In accordance with the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising, if you do not want to receive interest-based advertising, you may opt out by visiting www.aboutads.info/choices. Additionally, you may opt out of cookies used on our website to provide targeted advertising by opting out in our cookie settings tool. Please keep in mind that your selection is specific to the device, website, and browser you are using, and is deleted whenever you clear your browser's cache.

Browser and Device-Based Opt Out Features. Your browser or device may also include features that allow you to opt out of having certain information collected and used for interest-based advertising purposes.

Scope of Opt-Out. If you opt out of interest-based advertising, you may still see ads that are less tailored for you as you browse the internet.

Do Not Track. While we strive to offer you choices when you use our Services (as described below), because of a lack of standardization regarding Do Not Track signals we are not able to receive or honor “Do Not Track” signals from your web browser at this time. Instead, you can use the range of other tools to control information collection and use, including the cookie, analytics, and advertising controls described above.

7. YOUR CHOICES
We provide choices about how we collect, use and share information about you. The choices you make will not apply to your household or any affiliate members associated with your membership account. Each household member must opt out separately. If you have more than one account profile or email address, you must opt out for each one separately.

You can opt out of certain uses or sharing of your information by (a) using the chat feature on our website; (c) emailing us at: optout@brighttalent.com.

Third-Party Marketing. As described above, we may share your information with third parties for their own marketing purposes unless you have opted out of such sharing. You can opt out of this sharing by contacting us using the methods above.

Cookie Controls. Many web browsers are set to accept cookies by default. If you prefer, you can set your browser to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. See the Cookies section of this privacy statement for more details.

Analytics. Our analytics providers may provide options to opt-out of certain information collection or use. See the Cookies section of this privacy statement for more details.

Promotional Information and Emails. If you do not want to receive promotional communications from us, you can contact us using any of the methods above. You can also opt out from different types of promotional emails through the ‘unsubscribe’ link in those emails. If you opt out, we may still send you non-promotional emails.

Mobile Push Notifications/Alerts. We may send push notifications or alerts to your mobile device. You can stop these notifications by changing the settings on your mobile device.

SMS (Text) Messages. We will send you SMS (text) communications if you consent to receive them. We will also send you SMS (text) messages in case of emergency, and other limited (non-marketing) instances as permitted by law. You can reply “STOP” to any SMS (text) message to cancel at any time.

Updating, Reviewing or Correcting Online Information. You can update, review or correct your account information by emailing us at optout@brighttalent.com. You may also use the chat feature on our website.

8. PROTECTION OF PERSONAL INFORMATION
We aim to take reasonable steps to help protect your personal information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure and therefore we are unable to guarantee the security of your personal information. If you have reason to believe that your interaction with us is no longer secure, please let us know (see “Contact Us” below).

9. CALIFORNIA PRIVACY RIGHTS
If you are a California resident, beginning January 1, 2020 you have the right to make the following requests with respect to your personal information under the California Consumer Privacy Act (CCPA):

Access. You have the right to request that we disclose to you the personal information we have collected, used, disclosed or sold about you in the previous 12 months. You may submit an access request here.

Deletion. You can request that we delete your personal information that we collected from you to the extent required under CCPA and subject to certain exceptions. We retain personal information to provide you service, to comply with applicable laws and regulations and other permissible purposes. That means we may not be able to delete all of your personal information. You may submit a deletion request here.

Right to Opt-Out. You have the right to request to opt-out from future “sales” of your personal information. To do so, please email  us at optout@brighttalent.com. The law defines “sale” very broadly to include simply making data available to third parties in some cases. We do not sell or even provide access to your information to third parties for advertising or marketing purposes. We may however disclose personal or business information to the companies working with us to further develop and improve our services to you and others. If you do not wish for us to “sell” your personal information to other companies as defined under the CCPA, you can opt out and exercise your Do Not Sell My Information rights by contacting us using the methods above. 

You may designate an authorized agent to make requests on your behalf to exercise your rights under the California Consumer Privacy Act. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized that person to act on your behalf, and we will need you to verify your identity directly with us. Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. You must provide written authorization for the third parties to make an access or deletion request on your behalf. Finally, you have a right to not be discriminated against for exercising rights set out in the CCPA.

For assistance making a California access or deletion request, please email optout@brighttalent.com.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. We will not include employment related information in fulfilling your request.

10. Contact Us; Questions or Concerns
If you have any questions about this Privacy Policy please email us at optout@brighttalent.com.