2. The Information We Collect.
To provide our Services, and to otherwise conduct our business, we rely on information provided by, and collected from, our users. This information consists of the following:
2.1 Personal Information.
We collect certain information that identifies you as an individual, and any other information that we associate with it (collectively, "Personal Information"). The Personal Information we collect may include the following:
- Your name, phone number, email address, and other contact information;
- Your account username and password;
- The agency or organization that you represent and your title;
- Your geolocation information;
- Any information or feedback you provide to us through our Platform or via social media, email, or phone; and
- Your transactions with us.
In addition to the above, we may collect the following Personal Information in connection with your use of the Omni Lab Solution, if such Services are available to you:
- Courses taken;
2.2. Online Activity Information.
We also collect technical and device-related information through our Platform and third party analytics tools that we use (collectively, "Online Activity Information"). For example, we use your IP address, time and date of your visit, and your interactions within the Platform to monitor customer traffic patterns and site usage to help us improve your user experience and ensure the quality of our service to you. Subject to Section 2.2 (Treatment of Combined Information) below, we will treat Online Activity Information as Anonymous Information unless an applicable law establishes that Online Activity Information constitutes Personal Information.
2.3. Anonymous Information.
2.4 Treatment of Combined Information.
3. How We Collect Information.
3.1 Site Visitors.
We allow you to visit our Websites and review other information about our Services without revealing your identity or otherwise providing Personal Information. In that case, the only information that we collect from your visit will be Online Activity Information or Anonymous Information. As a casual site visitor, you decide whether to provide us with your Personal Information.
3.2 Account Registration.
In order to access certain information, products, and Services on our Websites that are limited to registered users, such as the Omni Lab Solution, we may require that you complete a registration process in order to create an account, and to obtain a username and password associated with that account. This process asks for certain Personal Information.
3.3 Contacting Brixon.
You can contact us with questions, comments, complaints, feedback, requests for information, or other communications. In order to communicate with us, you must provide certain Personal Information. We may use Personal Information and other information submitted to provide you with the information, products, and services that you have requested.
3.4 Information Received from Third Parties.
3.5 Collection of Personal Information Offline.
3.6 Submitted Content.
We may give you the ability through the Platform to engage with us and others in public exchanges, and this may include opportunities for you to customize your user profile and provide comments, feedback, images and audiovisual files, and other information and materials that you wish to share (collectively, "Submitted Content"). You agree that we may use and adapt your Submitted Content (including, but not limited to, your name, experiences with us, and other provided feedback) for these purposes and without the need for compensation – including disclosing Submitted Content to the public. We are not responsible for Personal Information you decide to include in Submitted Content, and we will not take down, remove, or edit Submitted Content, except as required by applicable law. If your Submitted Content includes Personal Information relating to others, you represent that you have full permission and authority to do so.
3.7 Employment Applications.
3.8 Omni Lab Solution.
We collect and use Personal Information in connection with your use of the Omni Lab Solution. Additional information regarding your use of the Omni Lab Solution is included in our end user license agreement, which you must agree to prior to using the Omni Lab Solution.
4. How We Collect Online Activity Information and Anonymous Information.
4.1 Logs; IP Addresses.
Either directly, or through our Service Provider, we may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your computer), your computer's name, the type and version of your web browser, referrer addresses, where the computer is routing from, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Platform is being used and for security and monitoring purposes.
4.2 Computer Configuration.
A cookie is a small amount of data that is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. For example, we may include cookies on our Websites and use them to recognize you when you return to our Platform. You may choose not to accept cookies; however, you may need to enable cookies if you wish to access certain personalized features of our Services.
We may send email messages, which use a "click-through URL" linked to content on our Platform. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and to measure the effectiveness of our customer communications. If you prefer not to be tracked simply do not click text or graphic links in the email, or notify us in accordance with Section 10 (Your Choices Regarding Your Personal Information).
5. How We Use this Information.
- To provide you with Services you request (on the Websites, by phone, in person, or otherwise);
- To allow you to post or provide Submitted Content;
- To communicate with you about your account and our Services, such as to respond to your inquiries, comments, or complaints that you provide to us;
- To create aggregated and/or de-identified statistical, information about our users or their web usage and disclose this statistical information when appropriate;
- To process payments you make with respect to our Services;
- To customize, enhance, and enrich your visit to and use of the Platform;
- To consider your submittals and other expressions of interest in connection with our career opportunities;
- To track access to, and use of, our Platform, and conduct data and other analyses, including anonymization and aggregation of Personal Information;
- To perform internal administration, auditing, operation, and troubleshooting for our Platform;
- To perform analytics, quality control, market research, and to determine the effectiveness of our Platform;
- To evaluate and improve our Platform and communications, and to develop and test new services and content; and
- To engage in the activities specified in Section 6 (How We May Disclose this Information).
- We may use Service Providers: (i) to fulfill your requests; (ii) to process and distribute email; and (iii) to manage activities related to our business. These Service Providers generally require access to your Personal Information in order to perform these services.
- We may use Service Providers to provide customer service (where applicable) and other types of support, such as to process and distribute email. These Service Providers generally require access to your Personal Information in order to perform these services.
- We may use analytics Service Providers to assist us in understanding and using Online Activity Information and other information that we collect via the Websites. A service we use in this regard is Google Analytics, and information concerning how Google uses the information is available at https://policies.google.com/privacy/partners. Opt-out options specific to Google Analytics are available at https://tools.google.com/dlpage/gaoptout.
- Our Platform may include links to third party website offering services that augment our Services.
- We may use Service Providers to anonymize and aggregate Personal Information in order to generate Anonymous Information.
We may also use information we collect as we believe to be necessary or appropriate for certain essential purposes, including to: (i) comply with applicable law and legal process; (ii) respond to requests from public and government authorities; (iii) detect, prevent, or investigate potential security incidents or fraud; (iv) provide important safety information; (v) facilitate the functionality of our Platform; (vi) enforce our terms and conditions; (vii) protect our operations or those of our affiliates; (viii) protect our rights, privacy, safety or property, security and/or that of our affiliates, you, or others; and (ix) allow us to pursue available remedies or limit the damages that we may sustain.
6. How We May Disclose This Information.
We share the information we collect only in the manner set out below.
6.1 Our Service Providers.
We engage third parties to perform functions on our behalf, such as maintaining the Platform, collecting information, responding to and sending email or other messages, and other functions useful to our business (collectively, the "Service Providers"). To this end, we may provide our Service Providers with Personal Information, Online Activity Information, and Anonymous Information. The following are examples:
We require our Service Providers to contractually commit to protect the privacy and security of the Personal Information they process on our behalf.
6.2 Questions of Harm; Legal Process.
We may disclose your Personal Information and Online Activity Information to third parties, including law enforcement agencies, attorneys, and private investigator organizations, where it is necessary, or where we have a good faith belief that it is necessary to: (i) comply with legal process; (ii) protect and defend our rights and property, including the Platform and associated content; (iii) protect against misuse or unauthorized use of our Platform; (iv) protect the personal safety or property of users or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and (v) cooperate with public and government authorities including, where required, authorities outside your jurisdiction. While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personal Information, then we will attempt to notify you within a reasonable amount of time unless such notification is not permitted.
6.3 Corporate Transactions.
6.4 Our Affiliates.
7. Disclosing Personal Information Where it is Not Specifically Requested.
If we have not specifically asked for your Personal Information, for example, in a particular portion of an online form, then you should not provide any Personal Information in that portion of the form.
8. Our Retention of Personal Information.
We retain Personal Information for the period of time necessary to fulfill the purposes for which we obtained the Personal Information and consistent with applicable law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).
9. Accuracy and Minimization of Personal Information.
We take reasonable steps (i) to maintain the accuracy of the Personal Information we process, and (ii) to limit the Personal Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.
10. Your Choices Regarding Your Personal Information.
10.1 Accessing and Updating Your Personal Information.
If you would like to review, correct, or update the Personal Information that you have provided to us, then please contact us as provided in Section 16 (Contact Us).
10.2 Deletion of Personal Information.
You may request that we delete your Personal Information. Note that deletion requests are subject to a number of limitations, for example, we may keep Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, to process transactions and facilitate you requests, and for other internal business purposes consistent with the terms under which it was collected.
10.3 Response to Requests.
Please be advised that Brixon will fulfill these requests in its reasonable discretion and in a manner consistent with any applicable law. Likewise, we will aim to complete such requests as soon as reasonably practicable and in a manner consistent with any applicable law. If you otherwise have concerns or objections with our processing of your Personal Information, please contact us as provided in Section 16 (Contact Us).
We recognize the sensitivity of your Personal Information and we have put in place security systems designed to prevent unauthorized access to, or disclosure of, Personal Information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personal Information in accordance with applicable law. However, due to the nature of internet communications and information technology, we cannot provide, and expressly disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
12. Notice of Privacy Rights to California Residents
California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for direct marketing purposes. The California "Shine the Light" law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their direct marketing purposes.
13. Advisory Regarding Participation by Children and Teens.
We want your feedback. If you have a suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 16 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state's consumer protection authority.
16. Contact Us.
17. Do Not Track Notice.
Our Websites do not change behavior when receiving "Do Not Track" signals from browser software.
19. International Considerations.
20. Effective Date.
20. COPYRIGHT AND LEGAL NOTICE.
Copyright © 2020 Brixon, Inc. All Rights Reserved.