Last Updated: September 10, 2018
at Brightcoin, Inc. (“BrightCoin,”
are committed to protecting the privacy of all our Users (“User,”
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
privacy matter to us and therefore for any queries and clarifications
please contact us at email@example.com.
PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT.
capitalized words, not defined herein, shall have the meaning
ascribed to them in our Terms of Service and/or the Investor
ACCESSING OUR WEBSITE AND BY USING OUR SERVICE, YOU ARE AGREEING TO
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
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.
THAT WE COLLECT
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.
we automatically collect.
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
you provide us.
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.
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.
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.
we collect from third-party sources.
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.
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.
is an exhaustive list of the cookies we use:
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
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.
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.
WE USE YOUR INFORMATION
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:
comply with our legal obligations.
prevent and investigate potentially prohibited or illegal
activities, and/or violations of our posted user terms.
process transactions and send notices about your transactions.
verify your identity by comparing your personal information against
send administrative or account-related information to you.
enforce our agreements with third parties.
resolve disputes, collect fees, and troubleshoot problems.
quality control and staff training.
enhance security, monitor and verify identity or service access,
combat spam or other malware or security risks.
provide you with services and customer support that you request.
better understand our customers and end-users and the way they use
and interact with our services.
provide a personalized experience, and implement the preferences you
communicate with you about our events or our partner events.
customize, measure, and improve our services and the content and
layout of our website and applications.
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.
WE SHARE YOUR INFORMATION
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.
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.
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.
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.
We Share Your Information With
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:
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.
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:-
right to be informed
right of access
right to rectification
right to erasure
right to restrict processing
right to data portability
right to object
rights in relation to automated decision making and profiling.
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”).
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.
can exercise this right at any time by writing to us using the
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.
Right to Rectification and Erasure
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”).
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
Right to Restrict Processing
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.
Right to Portability
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.
Right to stop receiving communications
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.
Right to object to automated decision making and profiling
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
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 firstname.lastname@example.org
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.
WEBSITE AND SERVICES
Website contains links to websites maintained by third parties.
Please be aware that these third-party websites are governed by their
are not responsible for the content or policies maintained by these
third-party websites you visit.
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.
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
CALIFORNIA PRIVACY RIGHTS
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
or write us at 440 North Wolfe road, Sunnyvale, CA.
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.
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.
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.
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
FOR USERS OUTSIDE THE UNITED STATES
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
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.
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
contact Brightcoin at email@example.com.
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
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.
you do not understand any of the terms or conditions of this, you may
inquire regarding the same via email at firstname.lastname@example.org.
practices, contact us at:
NOTE: IF YOU USE OUR WEBSITE AND/OR OUR SERVICES, YOU HAVE AGREED TO
TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE. IF YOU DO NOT
PLEASE DO NOT USE OUR WEBSITE OR OUR SERVICES, OR ESTABLISH AN