Privacy Policy

BRIGHTCOIN, INC.


PRIVACY POLICY

Last Updated: September 10, 2018


We at Brightcoin, Inc. (“BrightCoin,” “we,” “our,” or “us”), are committed to protecting the privacy of all our Users (“User,” “you,” or “your”)


This privacy policy (“Privacy Policy”), among other things, lets you know how we collect, process, use, disclose, and secure information from our Users who access and use our website i.e., www.brightcoin.us (“Website”), our Services.


Your privacy matter to us and therefore for any queries and clarifications please contact us at support@brightcoin.us.


PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT.


Initially capitalized words, not defined herein, shall have the meaning ascribed to them in our Terms of Service and/or the Investor Agreement.


BY ACCESSING OUR WEBSITE AND BY USING OUR SERVICE, YOU ARE AGREEING TO AND ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.IF YOU DO NOT AGREE WITH THE TERMS SET FORTH HEREIN, DO NOT REGISTER OR USE OUR WEBSITE AND SERVICES THEREUNDER. IF YOU USE THE SERVICES OFFERED HEREWITH, YOU ARE BOUND BY THIS PRIVACY POLICY AND ANY RELATED TERMS.


INTRODUCTION

This document (“Privacy Policy”), make up our commitment to protecting personal information we hold about our customers, prospective customers, newsletter subscribers, competition entrants, website users or any other data subject whose personal information we hold. Personal information as outlined in this policy is being processed by Brightcoin, Inc. In the event of any part of Brightcoin either being sold or going into receivership, we reserve the right to continue to share your data to third parties in accordance with the latest preferences you have provided. You will be informed should any change of ownership occur, and the new owner will manage your personal information preferences.


  1. INFORMATION THAT WE COLLECT

BrightCoin may collects both personally identifiable inform and non-personally identifiable information from its Users. We may collect the following information from you when you use our Website and our Services. The information so collected may be stored on our servers.


  1. Information we automatically collect.

When a User visits our Website, we automatically collect certain information including: (i) information about your interaction with our Website, including the the actions you take, the pages or other content you view or otherwise interact with, and the dates and times of your visits; and (ii) device information, such as your IP address, operating system information, and web browser and/or device type and language.


  1. Information you provide us.

We also receive information about you if you choose to provide it to us, such as when you register for and create an Account on our Website. This information may include your name, address, phone number, email address, photo, Social Security number, date of birth, net worth, income, status as an accredited investor, your biography, your picture, your ID/Passport and your website as well as information collected about your use of our services (such as when you enter our sites and how long you stay on them). If you choose to invest in a business through our Website, we will collect payment information from you, such as financial account information or payment card information, and we may collect information to verify your income, such as a bank statement or W-2 form. Please note that we do not store your payment card information, but we do store other financial information. If you choose to add an investment entity to your profile, we will also collect information about the entity.

If you would like to raise funding for your business with our Website, we collect information about you and your business, your fundraising terms, and payment information.

We also collect information when you post questions or comments on our Website, send or receive direct messages from other users, or when you contact us, including via email, phone, or social media.

  1. Information we collect from third-party sources.

In order to provide the services on our Website, including verifying your identity and other information you provide us, we collect information about our users from third parties and combine it with other information we receive from or about our users.


  1. Cookies.

When you visit our Website, we and our service providers collect certain information through the use of "cookies" and other technologies to better understand how our users navigate through our Website, learn what content is being viewed, and administer and improve our Website. Cookies are small text files that web servers place on an internet user’s computer that are designed to store basic information and to recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Website.


Below is an exhaustive list of the cookies we use:


Strictly Necessary Cookies – These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information

Performance Cookies – These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous.

Functional Cookies – These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages.



  1. HOW WE USE YOUR INFORMATION


Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes. Examples of how we may use this information include:


  • To comply with our legal obligations.

  • To prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms.

  • To process transactions and send notices about your transactions.

  • To verify your identity by comparing your personal information against third-party databases.

  • To send administrative or account-related information to you.

  • To enforce our agreements with third parties.

  • To resolve disputes, collect fees, and troubleshoot problems.

  • For quality control and staff training.

  • To enhance security, monitor and verify identity or service access, combat spam or other malware or security risks.

  • To provide you with services and customer support that you request.

  • To better understand our customers and end-users and the way they use and interact with our services.

  • To provide a personalized experience, and implement the preferences you request.

  • To communicate with you about our events or our partner events.

  • To customize, measure, and improve our services and the content and layout of our website and applications.


We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or services then the products provided by Brightcoin may not be available to you.


  1. HOW WE SHARE YOUR INFORMATION

We may share your information with businesses that you invest in. The information about you that we share with the businesses you invest in may include your public profile information and your address, email address, and Social Security number.


We use service providers to provide certain services to us, such as analytics services, fraud detection, payment processing, and advertising and marketing services. We only provide our service providers with the information necessary for them to perform these services. Our analytics providers may collect information about your online activities over time and across different online services when you use our Website.

In the event that BrightCoin is merged or sold, or in the event of a transfer or sale of some or all of our assets, we may disclose or transfer information we collect in connection with the negotiation and/or conclusion of such a transaction.

We may disclose information about you to third parties if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request, (b) to enforce our agreements, policies, or terms of service, (c) to protect the security or integrity of our Website, (d) to protect the property, rights, and safety of us, our users, or the public, (e) to respond in an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations.


  1. Who We Share Your Information With

Brightcoin has formed partnerships with a variety of carefully selected companies that we share data with in order to carry out the activities described in the section ‘How We Use Your Information. Below is a non-exhaustive list of our key partners:

  • Onfido

  • International Screening Solutions

  • AWuLaw.com

  1. USER CHOICES

You can update the information you provided us by accessing your account settings. Through your account settings, you can also hide some portions of your profile from other users or the general public on the Internet as well as hide your profile from search engines that collect information from our websites.


Brightcoin strives to abide by not only U.S and California regulations but also regulation set forth by GDPR. Under the GDPR including any implementing data protection legislation in the UK you have the rights shown below:-

  • Your right to be informed

  • Your right of access

  • Your right to rectification

  • Your right to erasure

  • Your right to restrict processing

  • Your right to data portability

  • Your right to object

  • Your rights in relation to automated decision making and profiling.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us using the and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request. You can exercise this right at any time by writing to us using the and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid. You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us to verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims. Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it. You can exercise this right at any time by writing to us and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format, if you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to stop receiving communications

You can also opt out of promotional email communications at any time by clicking on the unsubscribe link in an email your received from us. You can also update your communication preferences through your account settings on our Website. You can also write to us directly to stop receiving communications.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.You might contact us directly for any information regarding our automated decisioning making and profiling decisions.

Exercising your rights

If you wish to exercise any of these rights or simply wish to find out what information, if any, we hold that relates to you, you must make your request in writing by sending an email to support@brightcoin.us


You can help us to process your request quickly by providing us with information that will help us identify records we hold that relate to you. For example your name, address, email address, telephone number, subscriber id or in the case of information captured via cookies, the IP address of the device you have used.


  1. THIRD-PARTY WEBSITE AND SERVICES

Our Website contains links to websites maintained by third parties. Please be aware that these third-party websites are governed by their own privacy policies and are not covered by our Privacy Policy. We are not responsible for the content or policies maintained by these websites. Please familiarize yourself with the privacy policy of any third-party websites you visit.


  1. CHILDREN’S PRIVACY

Our Website and our Services is not intended for persons under 18 years of age. We request that people under the age of 18 do not use our Website and/or Services and also do not share any personal information with us.


Our Website and our Services is not intended for children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If we learn that we have collected the personal information from a child under the age of 13, we will take steps to delete the information. If you are aware that a child under 13 has provided us with personal information, please contact us at support@brightcoin.us.


  1. YOUR CALIFORNIA PRIVACY RIGHTS

BrightCoin does not sell, trade, or otherwise transfer to outside third parties your personal information. California Civil Code Section § 1798.83 permits users of our Website and our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@brightcoin.us or write us at 440 North Wolfe road, Sunnyvale, CA.


  1. DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls.


The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password or Account Key for access to certain parts of our Website and/or Services, you are responsible for keeping this password and Account Key confidential. We ask you not to share your password or Account Key with anyone.


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.


We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so within 72 hours of when a breach has been discovered



  1. NOTICE FOR USERS OUTSIDE THE UNITED STATES

As a global entity, Brightcoin may store, transfer, and otherwise process your personal information in countries outside of the country of your residence, including the United States and possibly other countries.


Brightcoin is responsible for the processing of personal information it receives and subsequently transfers to a third party acting as an agent on its behalf. Brightcoin will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. We will take all reasonable steps to ensure that personal information we process is limited to only what is relevant to the purposes for which it was collected and that it is accurate, complete, and up-to-date.


Brightcoin, Inc. commits to resolve European data subjects' complaints about their privacy and our collection, use or disclosure of their personal information in compliance with the EU. European data subjects with inquiries or complaints regarding this Privacy Policy should first contact Brightcoin at support@brightcoin.us.


  1. CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our Privacy Policy, on this page. If we make material changes to how we treat our User’s information, we will notify you by e-mail to the e-mail address specified in your Account and/or through a notice on the Website home page. The date the Privacy Policy was last revised/updated is identified at the top of the page. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.


We encourage you to review this Privacy Policy periodically.


If you do not understand any of the terms or conditions of this, you may inquire regarding the same via email at support@brightcoin.us.


  1. CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, contact us at:



PLEASE NOTE: IF YOU USE OUR WEBSITE AND/OR OUR SERVICES, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR THE TERMS OF SERVICE, PLEASE DO NOT USE OUR WEBSITE OR OUR SERVICES, OR ESTABLISH AN ACCOUNT.