This policy describes how we, BRIKKY BRAKS, use information (we refer to it as “Personal Data”) that you provide. Safeguarding your privacy and Personal Data is very important to us. We will not sell your Personal Data to anyone, nor will we transfer any of it to anyone except as provided in this policy. Contact us in case you wish to change, erase or make a complaint regarding our collection, storage, safeguarding or use of your Personal Data.
I. What kinds of Personal Data we collect
A. Personal Data collected. When you contact us, we might receive your email address and any personal information you wish to share in your message.
B. Personal Data collected when we communicate with each other. There may be times when you contact us or we contact you. In those cases, we may collect related to these communications, including the email address used, metadata associated with the communication (either email metadata or metadata created by our website contact forms), and any other information you share with us. “Metadata” refers to the information about other information. So, in the case of emails, it would include information about their origins, destinations and timing/creation dates.
II. How we use your Personal Data.
A. Personal Data collected when you contact us as per Section I(A). We use this information in order to respond or address the concerns you raise in your contact with us.
B. Personal Data collected when we communicate with each other as per Section I(B). We use this information to help us manage and improve our customer service.
III. How we collect this Personal Data
A. Personal Data collected when you contact us as per Section I(A). We collect this information from you when you communicate with us.
B. Personal Data collected when we communicate with each other as per Section I(B). We collect this information when we communicate with each other.
IV. Cookie Policy
A. Cookies/Tracking Technologies: Although we do not use tracking technologies internally, such as cookies, local storage, and pixel tags, it is possible that GoDaddy, as the host of our website and Vimeo, as the host of our videos, may use them for analytics and that they may share this information with us.
B. What are Cookies?
For almost any modern website or service such as ours to work properly, it needs to collect certain basic information on its users. To do this, a site will create files known as cookies. These are small files that are stored on its users’ computers and other devices. These cookies are designed to allow our website to recognize its users on subsequent visits, or to authorize other designated websites to recognize these users for a particular purpose.
Cookies do a lot of different jobs which make your experience of the internet much smoother and more interactive. For instance, they are used to remember your preferences on sites you visit often, to remember your user ID and the contents of your shopping baskets, and to help you navigate between pages more efficiently. They also help ensure that the advertisements that you see online are more relevant to you and your interests. Some data collected is designed to detect browsing patterns and approximate geographical location to improve user experience.
Some websites may also contain images called "web beacons" (also known as "clear gifs"). Web beacons only collect limited information, including a cookie number, a timestamp, and a record of the page on which they are placed. Websites may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular advertising campaign (for example by counting the number of visitors).
Information collected by cookies is now classed as Personal Data.
C. How do we use Cookies?
Although we do not currently collect any cookies or other tracking data, we may do so in the future depending on the growth of this business. In that event, we would use them for own purposes, such as to track our own performance. We might also use them to serve you content tailored to your own specifications, hopefully improving your overall experience of our products. Amongst other things, in the future, cookies might allow users to register to make comments, allow us to calculate how many visitors we have and how long they stay on our site.
We do our utmost to respect users’ privacy. In the event we decide to use cookies, we would use them to monitor and improve our site, services, and products. We may include links on our site to goods and services offered by third parties and we may be paid some commission if you subsequently decide to make a purchase. Cookies may be used to track your visits to third party sites to help ensure that we are paid the correct amounts. Please note that these commercial arrangements would not influence our editorial content in any way, but they would allow us to remember your preferences so that you don’t have to keep resubmitting the same information over and over. Cookies may be used to track your visits to third party sites to help ensure that we are paid the correct amounts.
Should we decide to use cookies, we believe that your experience of the site would be adversely affected if you opted out of those cookies. However, you will be free to do this through your web browser’s privacy settings.
D. What are the different types of Cookies and which ones would we use?
There are two types of Cookies:
· Persistent cookies remain on a user’s device for a set period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
· Session cookies are temporary. They allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Once you close the browser, all session cookies are deleted.
Cookies also have, broadly speaking, four different functions and can be categorized as follow: ‘strictly necessary’ cookies, ‘performance’ cookies, ‘functionality’ cookies and ‘targeting’ or ‘advertising’ cookies.
Strictly necessary cookies are essential to navigate around a website and use its features. Without them, you wouldn’t be able to use basic services like registration or shopping baskets. These cookies do not gather information about you that could be used for marketing or remembering where you’ve been on the internet.
Examples of how we might use ‘strictly necessary’ cookies include:
· Setting unique identifiers for each unique visitor, so site numbers can be analyzed.
· Allowing you to sign in to our website as a registered user (if we opt to provide this functionality).
Performance cookies collect data for statistical purposes on how visitors use a website, they don’t contain personal information such as names and email addresses and are used to improve your user experience of a website.
The following are some examples of how we might use performance cookies:
· Gathering data about visits to the website, including numbers of visitors and visits, length of time spent on the site, pages clicked on or where visitors have come from.
· For comparison with other websites using data collected by industry-accepted measurement and research companies.
Information supplied by performance cookies would help us to understand how you use the website; for example, whether or not you have visited before, what you looked at or clicked on and how you found us. We can then use this data to help improve our products or services. We might use independent analytics companies to perform these services for us and when this is the case, these cookies may be set by a third-party company (third party cookies).
We also might combine the data from the web analytics services and their cookies with the information you have supplied to us, so that we can make your experience more personal by recommending certain products to you based on your reading behavior. We would only do this if you have given us permission to communicate with you.
Functionality cookies allow users to customize how a website looks for them: they can remember usernames, language preferences and regions, and can be used to provide more personal services like local weather reports and traffic news.
Here are some examples of how we functionality cookies can be used:
· Storing your user preferences on Your Account and/or Profile pages (should there come a time when we set up the ability to set up user accounts); and
· Remembering if you’ve been to the site before so that messages intended for first-time users are not displayed to you.
Advertising and targeting cookies might be used to deliver advertisements more relevant to you but can also limit the number of times you see an advertisement and be used to chart the effectiveness of an ad campaign by tracking users’ clicks. They can also provide security in transactions. They are usually placed by third-party advertising networks with a website operator’s permission but can be placed by the operator themselves. They can remember that you have visited a website, and this information can be shared with other organizations, including other advertisers. They cannot determine who you are though, as the data collected is never linked to your profile.
The two main ways we may use advertising and targeting cookies are set out below:
· Interest-based advertising (or online behavioral advertising) is where cookies are placed on your device by our third-party service providers which remember your web browsing activity and group together your interests in order to provide you with targeted advertisements which are more relevant to you when you visit our website or use our service. Your previous web browsing activity can also be used to infer things about you, such as your demographics (age, gender etc.). This information may also be used to make the advertising here more relevant to you.
· ‘Retargeting’ is a form of interest-based advertising that enables our advertising partners to show you advertisements selected based on your online browsing activity away from the website. This allows companies to advertise to people who previously visited their website. These cookies will usually be placed on your device by third-party advertising networks and we have listed the main third-party networks we work with below.
Without these cookies, online advertisements you encounter will be less relevant to you and your interests.
E. How do I control my Cookies?
You should be aware that any preferences will be lost if you delete all cookies and many websites will not work properly or you will lose some functionality. We do not recommend turning cookies off when using our website for these reasons.
Most browsers accept cookies automatically, but you can alter the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. Generally you have the option to see what cookies you’ve got and delete them individually, block third party cookies or cookies from particular sites, accept all cookies, to be notified when a cookie is issued or reject all cookies. Visit the ‘options’ or ‘preferences’ menu on your browser to change settings, and check the following links for more browser-specific information.
Cookie settings in Microsoft Edge
F. Enabling the DO NOT TRACK (DNT) web browser feature
Instead of changing your browser settings to prevent Cookies from being stored on your computer or device, we suggest using the Do Not Track (DNT) feature built into your web browser. We honor DNT requests and will not track anyone who has this setting toggled to an on state. You can learn more about the DNT feature in your browser by visiting: https://allaboutdnt.com/
G. Managing advertising Cookies
Please note that if you want to opt out from receiving targeted advertising, this does not mean that you will receive less advertising when you use our website. This just means that the advertising you see will not be as customized to you.
You can visit the Internet Advertising Bureau’s consumer advice site, http://youronlinechoices.com/. This will give you a list of all cookies that are currently set on your device and how to opt out of each of them. Please note that this list will contain more networks than just found on our website and/or service.
We have also set out links below to some of the specific partners we work with who set cookies on our websites, and therefore on your computer, each of which have instructions on how to opt out of their cookies.
Google – http://www.google.com/ads/preferences/html/opt-out.html
V. Sharing your Personal Data with others
A. Internally:
We may disclose your Personal Data within our company structure, including our subsidiaries, member/parent companies and their subsidiaries (should we ever have any) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
B. Professional service providers:
We may disclose your Personal Data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
C. Vendors, suppliers and other third-parties:
We will never sell your Personal Information to third-parties for any reason. However, it is possible that should we become bankrupt and our assets sold (of which your Personal Data, as an asset, may be included), a third-party purchaser of those assets may behave otherwise.
D. Legal compliance:
In addition to the specific disclosures of Personal Data set out in this Section V, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
VI. International transfers of your Personal Data
Our offices are located in the United States. However, we recognize the possibility that some of our users may be located in the European Union, and thereby potentially protected by its General Data Protection Regulation (GPDR). It is our opinion that our Privacy Policy and procedures designed to protect your privacy are compliant with the European Union’s GPDR as well as relevant United States legal requirements. However, because the very nature of our services utilize third-parties such as web and video hosting services, we cannot guaranty that others won’t misuse your Personal Data that they collect.
VII. Retention of your Personal Data
This Section VII sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of Personal Data.
We will retain your Personal Data indefinitely, unless we close the business or you instruct us to delete it. In the event that you instruct us to delete your Personal Data, we will do as soon as we reasonably can after such a request. We may also retain your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
VIII. Your Right to access, change or delete your Personal Data
A. Although we are based in the United States, we strongly believe that providing our customers and contacts with more control over their Personal Data is beneficial to our users and to society in general. That is why we welcome compliance with the European Union’s GPDR. Below, we have summarized your rights under the GPDR. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, if you have any questions about them, feel free to contact us. If you wish, we can direct you to the relevant laws and regulations as well as governmental authorities that can provide you with further guidance for a more detailed explanation of your rights.
B. Your principal rights with respect to your Personal Data under GPDR are:
1) the right to access;
2) the right to rectification;
3) the right to erasure;
4) the right to restrict processing;
5) the right to object to processing;
6) the right to data portability;
7) the right to complain to a supervisory authority; and
8) the right to withdraw consent.
C. You have the right to confirmation as to whether or not we process your Personal Data and, where we do, access to the Personal Data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. As long as the rights and freedoms of others are not affected, we will supply to you a copy of your Personal Data if you request it of us. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request your Personal Data that we maintain by simply contacting us through this website.
D. You have the right to have any inaccurate Personal Data about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about you completed.
E. In some circumstances you have the right to delete your Personal Data without undue delay. Those circumstances include: the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
F. In some circumstances you have the right to restrict the processing of your Personal Data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the Personal Data for the purposes of our processing, but you require Personal Data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your Personal Data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
G. You have the right to object to our processing of your Personal Data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for any of the following: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the Personal Information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
H. You have the right to object to our processing of your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your Personal Data for this purpose.
I. You have the right to object to our processing of your Personal Data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
J. To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary (i) in order for us to provide you with products and services, or (ii) for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
and such processing is carried out by automated means, you have the right to receive your Personal Data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
K. If you consider that our processing of your Personal Data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. In the United States, you may file a complaint with the Federal Trade Commission. More information can be found at https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc. If you live in the EU, you may file a complaint in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
L. To the extent that the legal basis for our processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
M. You may exercise any of your rights in relation to your Personal Data by contacting us through the website.
IX. Amendment
A. We may update this policy from time to time by publishing a new version on our website.
B. You should check this page occasionally to ensure you are happy with any changes to this policy.
C. We may notify you of changes to this policy by email or through the private messaging system on our website.
X. Our Details
A. This website and the BRIKKY BRAKS product intellectual property are owned and operated by Eric J. Rotbard.
B. We are a sole proprietorship, and our address is 399 Knollwood Road, Suite 210, White Plains, New York 10603.
C. You can contact us:
1) by mail to the postal address given above; or
2) by using our website contact form.
D. Our Data protection officer’s contact details are Eric J. Rotbard with the same contact information as above provided.
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