Keenwawa's Privacy Policy

Last updated: October 2020

keenwawa, inc. dba Brightloom (“Brightloom”, “We”, “Us”, or “Our”) respects You and Your privacy and is committed to protecting it. This policy describes the types of information We may collect from You or that You may provide when You visit the website www.brightloom.com (the “Website”) and Our practices for collecting, using, maintaining, protecting, and disclosing that information (the “Privacy Policy”).

Please read this Privacy Policy carefully to understand Our policies and practices regarding Your information and how We will treat it. If You do not agree with our policies and practices, Your choice is not to use the Website. By accessing or using the Website, You agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Introduction

This Privacy Policy applies to information We collect:

  • On the Website;
  • In email, text, and other electronic messages between You and the Website (or You and Brightloom); and/or
  • In relation to Brightloom’s marketing activities.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Brightloom or any third party; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

In addition, this Privacy Policy does not apply to the data that Brightloom’s customers control and request Brightloom to process (which may include the customers’ end-user data) as part of Brightloom’s products and services. Such end-user data is governed by Brightloom’s separate agreement(s) with those customers.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of Our Website, including information:

  • By which You may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which You may be contacted online or offline (“Personal Information”);
  • That is about You but individually does not identify You; and/or
  • About Your internet connection, the equipment You use to access Our Website, and usage details.

We collect this information:

  • Directly from You when You provide it to Us;
  • Automatically as You navigate through the site (which may include usage details, IP addresses, and information collected through cookies, Web beacons, and other tracking technologies); and/or
  • From third parties, for example, Our business partners.

Information You Provide to Us

The information We collect on or through the Website may include:

  • Information that You provide by filling in forms on the Website;
    • This includes information provided at the time of requesting a demo, requesting further services, when You enter a contest or promotion sponsored by Us, and/or when You report a problem with Our Website (and may include such information as Your first and last name, company name, job title, work email address, phone number, or similar information);
  • Records and copies of Your correspondence (including email addresses) if You contact Us;
  • Your responses to surveys that We might ask You to complete for research purposes;
  • Information You provide to Brightloom in the course of Brightloom’s marketing, sales, and customer service activities; and/or
  • Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies

As You navigate through and interact with Our Website, We may use automatic data collection technologies to collect certain information about Your equipment, browsing actions, and patterns, including:

  • Details of Your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that You access and use on the Website; and/or
  • Information about Your computer and internet connection, including Your IP address, operating system, and browser type.

The information We collect automatically may include Personal Information. It helps Us to improve the Website and to deliver a better and more personalized service, including by enabling Us to:

  • Estimate Our audience size and usage patterns;
  • Store information about Your preferences, allowing Us to customize Our Website according to Your individual interests;
  • Speed up Your searches; and/or
  • Recognize You when You return to the Website.

The technologies We use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of Your computer. You may refuse to accept browser cookies by activating the appropriate setting on Your browser; however, if You select this setting, You may be unable to access certain parts of Our Website. Unless You have adjusted Your browser setting so that it will refuse cookies, Our system will issue cookies when You direct Your browser to Our Website.
  • Web Beacons. Pages of Our Website and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website are served by third parties. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about You when You use Our website. The information they collect may be associated with Your Personal Information or they may collect information, including Personal Information, about Your online activities over time and across different websites and other online services.

How We Use Your Information

We use information that We collect about You or that You provide to Us, including any Personal Information:

  • To present Our Website and its contents to You;
  • To provide You with information that You request from Us;
  • To fulfill any other purpose for which You provide it;
  • To notify You about changes to Our Website or any products or services We offer or provide though it;
  • To allow You to participate in interactive features on Our Website;
  • In any other way We may describe when You provide the information; and/or
  • For any other purpose with Your consent.

We may also use Your information to contact You about goods and services that may be of interest to You. If You do not want Us to use Your information in this way, please email [email protected].

We will not use Your Personal Information We collected for materially different, unrelated, or incompatible purposes without providing You notice.

Disclosure of Your Information

We may disclose aggregated information about Our users, and information that does not identify any individual, without restriction.We may disclose Personal Information that We collect or You provide as described in this Privacy Policy: 

  • To contractors, service providers, and other third parties We use to support Our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which We disclose it to them;
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Brightloom’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which
  • Personal Information held by Brightloom about Our Website users is among the assets transferred;
  • To fulfill the purpose for which You provide it; and/or
  • For any other purpose disclosed by Us when You provide the information.

We may also disclose Your Personal Information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply Our Website Terms of Use https://www.brightloom.com/terms and other agreements.
  • If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of Brightloom, Our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide You with choices regarding the Personal Information You provide to Us. We have created mechanisms to provide You with the following control over Your information: 

  • Tracking Technologies and Advertising. You can set Your browser to refuse all or some browser cookies, or to alert You when cookies are being sent. 
  • Promotional Offers from Brightloom. If You do not wish to have Your email address used by Brightloom to promote Our own or third parties’ products or services, You can opt out by emailing [email protected]. If We have sent You a promotional email, You may send Us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Brightloom as a result of a product purchase, product service experience, or other transactions.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect Personal Information from children under 13. If You are under 13, do not use or provide any information on the Website or on or through any of its features. If We learn We have collected or received Personal Information from a child under 13 without verification of parental consent, We will delete that information. If You believe We might have any information from or about a child under 13, please contact Us at: [email protected].

International Transfer

Brightloom uses data servers in the United States to provide the Website and services. You understand that by using the Website and Brightloom services, Your personal data will be transferred to the United States, and You consent to such transfer.

Data Security

We have implemented measures designed to secure Your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although We do Our best to protect Your Personal Information, We cannot guarantee the security of Your Personal Information transmitted to our Website. Any transmission of Personal Information is at Your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Your Rights and Choices Under the California Consumer Privacy Act (“CCPA”)

Right to Know and Data Portability

You have the right to request that We disclose certain information to You about Our collection and use of Your Personal Information over the past 12 months. Once We receive Your request and confirm Your identity, We will disclose to You, as applicable:

  • The categories of Personal Information We collected about You;
  • The categories of sources for the Personal Information We collected about You;
  • Our business or commercial purpose for collecting that Personal Information;
  • The categories of third parties with whom We share that Personal Information;
  • If We sold or disclosed Your Personal Information for a business purpose, two separate lists disclosing:
    • sales, identifying the Personal Information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained; and/or
  • The specific pieces of Personal Information We collected about You (also called a data portability request).

We do not provide a right to know or data portability disclosure for business-to-business Personal Information.

Right to Delete

You have the right to request that We delete any of Your Personal Information that We collected from You and retained, subject to certain exceptions. Once We receive Your request and confirm Your identity, We will review Your request to see if an exception allowing Us to retain the information applies. We may deny Your deletion request if retaining the information is necessary for Us or Our service provider(s) to:

  • Complete the transaction for which We collected the Personal Information, provide a good or service that You requested, take actions reasonably anticipated within the context of Our ongoing business relationship with You, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform Our contract with You;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if
  • You previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us;
  • Comply with a legal obligation; and/or
  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

We will delete or de-identify Personal Information not subject to one of these exceptions from Our records and will direct Our service providers to take similar action.

We do not provide these deletion rights for business-to-business Personal Information.

Exercising Your Rights to Know or Delete

To exercise Your rights to know or delete described above, please submit a request by emailing Us at [email protected]. Only You, or someone legally authorized to act on Your behalf, may make a request to know or delete related to Your Personal Information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Information or an authorized representative.
  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

We cannot respond to Your request or provide You with Personal Information if We cannot verify Your identity or authority to make the request and confirm the Personal Information relates to You.

We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We will confirm receipt of Your request within ten (10) business days. If You do not receive confirmation within the 10-day timeframe, please contact [email protected].

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time (up to another 45 days), We will inform You of the reason and extension period in writing.

If You have an account with Us, We may deliver Our written response to that account. If You do not have an account with Us, We will deliver Our written response by mail or electronically, at Your option.

Any disclosures We provide will only cover the 12-month period preceding Our receipt of Your request. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide Your Personal Information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to Your verifiable consumer request unless it 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 before completing Your request.

Non-Discrimination

We will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, We will not:

  • Deny You goods or services;
  • Charge You different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide You a different level or quality of goods or services; or
  • Suggest that You may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, We may offer You certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive We offer will reasonably relate to Your Personal Information’s value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires Your prior opt-in consent, which You may revoke at any time.

Contact Information

If You have any questions or comments about this notice, the ways in which Brightloom collects and uses Your information described here, Your choices and rights regarding such use, or wish to exercise Your rights under California law, please do not hesitate to contact Us at [email protected].