Effective Date: January 1, 2020
This Policy describes:
- Personal Information We Collect
- How We Collect Your Personal Information;
- How We Use Your Personal Information;
- How We Share Your Personal Information With Third Parties;
- How We Protect Your Personal Information
- Ability to Access, Update and Correct Personal Information
- California Privacy Rights
- Changes to the Policy; and
- Questions About This Policy
INFORMATION WE COLLECT
Bright Future Financial collects information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household (“Personal Information”). Bright Future Financial also collects non-Personal Information that cannot be linked or associated with any individual person or household. When non-Personal Information is combined with other information so that it does identify an individual person, we treat that combination as Personal Information. We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:
- Identifiers such as your first name, last name, alias, username or similar unique personal identifier, account name, online identifier, and/or date of birth.
- Contact Information such as your billing address, delivery address, email address and telephone numbers.
- Financial Information such as bank account and routing numbers, credit or debit card information, payment details, or PayPal payment information.
- Employment Information such as your company name.
- Profile Data such as user name, password, details about the products you have purchased, payments you have made, and/or other details of products and services you have purchased from us in the past, purchase or product preferences, feedback and survey responses.
- Biometric Data such as your fingerprint.
- Technical Information such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
- Usage Data includes information about how you use our Services.
- Marketing and Communications Information such as marketing campaign data, click throughs, your preferences and consent in receiving marketing from us and our third parties, and your communication preferences.
Children’s Privacy. The Services are intended for adult use only and is not directed towards children, minors, or anyone under the age of 18. If you are under the age of 13, you are not authorized to provide us with any Personal Information. If the parent or guardian of a child under 13 believes that the child has provided us with any Personal Information, the parent or guardian of that child should contact us at the email address below and to have this Personal Information deleted from our files.
HOW WE COLLECT YOUR PERSONAL INFORMATION
Information You Provide To Us:
Bright Future Financial may collect Personal Information from you that you voluntarily provide to us in various ways, including, but not limited to:
- Create an account with us
- Place an order or purchase products from us or otherwise use our Services
- Submit a Contact Us form
- Use the chat feature or other interactive tools on our website
- Call, email, or otherwise communicate with us
- Otherwise interact with the Services
Information We Collect When You Use Our Services
Automated technologies or interactions. As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. When you access and use our Services from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type.You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
Information We Collect From Third Parties
We collect Personal Information from various third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.
Third Party Service Providers. We collect Personal Information from service providers including where we operate accounts on third-party platforms, such as call center and email platforms, and social media platforms.
Third Party Advertising Partners. We collect Personal Information received from third party advertising partners, including partners who host and manage various online advertisements.
Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For more information on Google Analytics, visit https://support.google.com/analytics.
Third Party Cookies. We may engage third-party service providers, including Google and Facebook, to serve ads to you about our products and services as you browse the Internet. These third-party providers may use their own cookies tags to track your online activities and purchases in order to deliver targeted advertising based on your interests.
Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a Do Not Track (“DNT”) feature that signals to the websites that you visit that you do not want to have your online activity tracked. At this time, our website does not respond to DNT signals. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
HOW WE USE YOUR PERSONAL INFORMATION
Our primary purpose in collecting Personal Information is to provide you with a safe, smooth, efficient, and customized experience. We use your Personal Information for the following business purposes:
- Collect and process payments and complete transactions
- Provide the products, services, and customer support you request
- Verify your identity and account information in connection with products or services you request
- Provide you with recommendations for products and services that we believe would be of interest to you
- Provide you with our newsletter if you have subscribed to it
- Assist you with setting up and managing your customer account with us
- Resolve disputes
- Troubleshoot problems
- Enforce our Terms and Conditions and the terms of this Policy
- Customize, measure and improve our services and content
- Inform you about our products, services, updates and promotional offers
- To protect our interests, including establishing, exercising and defending legal rights and claims
- As necessary to comply with legal requirements, to prevent fraud, to co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities
- For purposes disclosed at the time you provide your information or as otherwise set forth in this Policy
HOW WE SHARE YOUR PERSONAL INFORMATION
We share your Personal Information with third parties only in the ways that are described in this Policy and with our business partners, suppliers and sub-contractors in order to provide you with our Services and perform any contract we enter into with them or you.
Information You Instruct Us to Share. You may be presented with an option on our Service to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.
Service Providers. We may use third-party service providers to perform certain business services and may disclose Personal Information to such service providers as needed for them to perform these business services. Service providers are only allowed to use, disclose or retain the Personal Information to provide these services and are prohibited from selling Personal Information. Business services provided include, but are not limited to, hosting services, software as a service, document management services, communications services such as email, text, and chat services, software and website development services, collection services, payment processing services, accounting and audit services, compliance services, quality control services, analytics services, call center services, and marketing services.
Internal Third Parties. We may share Personal Information with our parent company, subsidiaries, successors, assigns, licensees, affiliates, or business partners and others, including where disclosure of your Personal Information is needed to protect the employees, independent contractors, officers, directors, members, users, or shareholders of Bright Future Financial who may use the Personal Information for the purposes described above.
Business Transactions. We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Policy.
Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
Sales of Personal Information. Like most companies, we allow certain third party advertising partners to place tracking technology such as cookies and pixels on our websites. This technology allows these advertising partners to receive information about your activities on our website, which is then associated with your browser or device. These companies may use this data to serve you more relevant ads as you browse the internet. Under some state laws, sharing data for online advertising may be considered a “sale” of information.
COMMUNICATIONS AND OPT OUT
By establishing an account, making a purchase, or registering to receive the Bright Future Financial Newsletter, you consent to receive periodic commercial/promotional email communications from us. You may opt-out of receiving such promotional communications at any time by following the unsubscribe instructions contained in each email, or by contacting our customer service department. This opt out will not apply to operational or informational emails related to your use of our Services. You may continue to receive promotional email messages for a short period while the we process your request.
HOW WE PROTECT YOUR PERSONAL INFORMATION
Bright Future Financial transmits information via industry standard secure server (SSL) provided by Trustwave. This SSL creates the secure and encrypted https:// website address for our important pages like Checkout and the My Account area. When you see the https:// website address, you know the information you are in-putting is protected and secure. We also comply with payment card industry data security standards that require merchants to implement security measures for credit card information. We never have access to your credit card information, as it is tokenized following PCI-compliant standards.
We have implemented and maintain generally accepted industry standards to protect against the unauthorized access, use, modification, destruction or disclosure of your Personal Information both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
ABILITY TO ACCESS, UPDATE AND CORRECT PERSONAL INFORMATION
Bright Future Financial wants your Personal Information to be complete and accurate. By using the Services, you represent and warrant that all information you provide on any registration form or otherwise in connection with your use of the Services will be complete and accurate, and that you will update that information as necessary to maintain its completeness and accuracy.
CALIFORNIA PRIVACY RIGHTS
California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Upon verification of your identity you may:
- No more than twice in any 12-month period, request disclosure of the following information:
- Categories of Personal Information we collect.
- Categories of sources from which Personal Information is collected.
- Categories of Personal Information sold or disclosed to third parties.
- Categories of third parties with whom such Personal Information is sold or disclosed.
- Business or commercial purpose for collecting or selling Personal Information.
- Specific pieces of Personal Information we collect.
- Request deletion of your Personal Information, subject to the exceptions provided by law.
- Opt-out from having your Personal Information sold to third parties, if applicable.
Please note that these rights apply only to select California consumers and exclude job applicants, employees, and business contacts. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information.
The verifiable consumer request must:
- Include your full legal name and phone number, which we will need to contact you in order to verify that 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. Making a verifiable consumer request does not require you to create an account with us. One of our representatives will contact you in order to verify your identity.
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, 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 ).
- 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.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
The CCPA provides the right to be free from discrimination if you choose to exercise your rights under the statute, and we will not discriminate by:
- Denying you goods or services.
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Providing you a different level or quality of goods or services.
- Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights. California residents have the right to receive information that identifies any third party companies or individuals that Bright Future Financial has shared your Personal Information with in the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting us at the address below.
CHANGES TO PRIVACY THE POLICY
QUESTIONS ABOUT THIS POLICY
You may contact Bright Future Financial directly if you have any questions about our Policy. Please contact our Compliance Officer 6310 San Vicente Blvd., Los Angeles, CA 90048 or e-mail firstname.lastname@example.org