Last updated: April 13, 2021
Effective Date: April 13, 2021
- Register and open an account with us as a publisher or retail partner;
- Access the BrandCycle proprietary platform;
- Make or receive a payment;
- Visit our branded social media pages;
- Visit our offices;
- Receive communications from us, including emails, phone calls, texts or fax; and
- Register for, attend or take part in our events, webinars, or contests.
What Personal Information Do We Collect and How Do We Use It?
Information we collect automatically – You can browse the Site without providing us with any information, but we gather some statistical data to understand how the Site is used, such as the Internet Protocol (IP) address of a computer requesting a page, the pages requested, computer and connection information such as device and browser type and operating system. We do not associate this statistical information with your Personal Information that we otherwise collect. We may use third party analytics providers to help us understand and use this statistical data.
Information you provide directly – Providing Personal Information such as your name or email address is entirely voluntary.
For example, when you register and open an account as a publisher or retail partner, we ask that you provide your name, website, address, phone number and information about your business (for example, your business model, target audience, traffic, social media profiles, etc.). You will also need to register and set up an account to access our proprietary platform. To create an account, you will need to create a User ID and unique password. We collect this information to set up and manage your account as one of our publishers or retail partners. We also use this information to respond to your inquiries and to send you informational and promotional emails and updates.
We retain Personal Information only for as long as necessary to provide the requested services, comply with our legal obligations, resolve disputes, and enforce our agreements.
We do not collect any “special categories” of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
If you believe that your Personal Information has been provided to us improperly or want to exercise your rights relating to your Personal Information, please contact us as described below.
The following cookies are deployed on the Website:
- Strictly Necessary Cookies: These cookies are strictly necessary to provide the Website. For example, they are used to authenticate and identify returning users.
- Performance and Functionality Cookies: These cookies provide statistical information on site usage, such as web analytics. They also help us to personalize and enhance your online experience.
Just like any other usage information we collect, information from cookies allows us to improve the Site and customize your online experience. You can set your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. See www.allaboutcookies.org to learn how to disable cookies on your browser or otherwise opt out of cookies. if you set your browser to disable all cookies or opt out, some features of the Website may not function properly.
We also use web beacons and pixels on Site and in emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies to operate and improve our Site and marketing emails.
The Site uses Google Analytics to help us manage and improve the Site and our services. Google provides a Browser Add-On that allows you to opt-out by downloading and installing the add-on for your web browser, available at https://tools.google.com/dlpage/gaoptout.
How Do We Protect Your Information?
We have implemented reasonable precautions to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, your Personal Information is retained in secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.
Be advised, however, no method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee the absolute security of information we collect and retain.
If you establish an account with us, please do not provide your login information, including your password, to another person. We cannot be responsible for a data breach or other incident if a password is used by unauthorized persons. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions.
Do We Disclose Personal Information to Third Parties?
We do not disclose your Personal Information to third parties except to trusted third parties that enable us to operate the Site and conduct our business. These third partis include our contracted service providers and professional advisors, who provide services such as IT and system administration and hosting, payment processing, research and analytics, marketing, legal and accounting services and customer support. These service providers are contractually obligated to protect the security of Personal Information we provide to them and not use it for any other purpose or party.
We may also disclose your information to our retail partners and/or publishers that may be a good referral or revenue source for your business.
We may also disclose your information when we believe release is appropriate to comply with the law, enforce our Site policies and terms, detect or prevent fraud, security or technical issues, or protect our or others’ rights, property, or safety. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
We may provide non-personally identifiable visitor information to other parties for marketing, advertising, or other uses.
If our assets are merged with or purchased by a third party, your Personal Information will be transferred to that third party.
Third Party Sites and Links
Social Media Features
Our Site includes features from social media websites such as the Facebook Like button and features on Twitter, Google+ and Instagram that run on our Site. Please note that our Site is not sponsored or endorsed by Facebook, Twitter, Google+ or Instagram, which are trademarked and owned by third parties and not by us. These features may collect your IP address or other Personal Information, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly.
Located in the United States
BrandCycle is located in the United States and our Site is owned and operated by us in the United States. If you are located outside the United States, your Personal Information may be collected, transferred to and stored by us in the United States and by our affiliates and categories of third parties disclosed above, which are based in the United States other countries. Therefore, your Personal Information may be processed outside your jurisdiction and that may not provide for the same level of data protection as your jurisdiction, such as the EEA. We ensure that the recipient of your Personal Information offers an adequate level of protection and security, for instance by entering into the appropriate data processing agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulator. Because our servers that store your information are located in the United States, your information may be available to US government entities or agencies under a lawful court order or other legal process in the US.
The Legal Basis for Using EEA Personal Data – For residents of the European Economic Area (EEA), we advise that your Personal Information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. The United States has not sought or received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (GDPR). Our legal basis for collecting and using your Personal Information is to do so with your consent; where we need the Personal Information for performance of a contract or requested service, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the Personal Information in question. If we collected your Personal Information with your consent, you may withdraw your consent at any time.
Our retention of your Personal Information and any subsequent communications are based on our legitimate interest in providing you with new and potentially relevant materials based on your geography, role, or company. As always, you can elect to opt out from receiving such future communications.
To the extent that we transfer Personal Information from the EEA to a jurisdiction outside the EEA that has not been adduced by the European Commission as providing adequate data protections (such as the United States), we will ensure that such Personal Information is safeguarded through appropriate contractual terms or other approved mechanisms.
Rights for EEA Residents – If you are a resident of the EEA, you have the right to:
- Find out if we use your personal information, to access your Personal Information, and receive copies of your Personal Information.
- Withdraw any express consent that you have provided to the processing of your Personal Information at any time without penalty.
- Access your Personal Information and have it corrected or amended if it is inaccurate or incomplete.
- Obtain a transferable copy of some of your Personal Information which can be transferred to another provider when the Personal Information was processed based on your consent.
- If you believe your Personal Information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Information, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
- Request your Personal Information be deleted or restricted under certain circumstances. For example, if is using your Personal Information on the basis of your consent and has no other legal basis to use such, you may request your Personal Information be deleted when you withdraw your consent.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
If we ask you to provide Personal Information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your Personal Information is required and if not, the consequences of not sharing your Personal Information with us. Similarly, if we collect and use your Personal Information in reliance on our or a third party’s legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.
We endeavor to apply suitable safeguards to protect the privacy and security of your Personal Information and to use it only consistent with your relationship with us and the practices described in this Privacy Information.
To withdraw consent or exercise these rights, please contact us via email at firstname.lastname@example.org.
If you are not satisfied with our response, or believe we are processing your Personal Information in violation of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data Protection Authority) or other appropriate governmental authority in your EEA Member State. A list of Supervisory Authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en.
You may request access to or correction of your Personal Information, or withdraw consent to our collection, use or disclosure of your Personal Data, by contacting at email@example.com. These rights are subject to applicable contractual and legal restrictions and reasonable notice. We may take reasonable steps to verify your identity before honoring any such requests.
California Do Not Track Disclosures/Your California Privacy Rights
If you are a resident of the State of California, under California Civil Code sections 1798.83-1798.84 (“Shine The Light” law), you have the right to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for direct marketing purposes. Since we do not share personal Information with third parties for direct marketing purposes, we are exempt from this requirement.
For California residents under the age of 18 and registered users of our Site, California law (Business and Professionals Code § 22581) provides that you can request the removal of content or information you posted on Websites. Any such request should be sent to us at firstname.lastname@example.org along with a description of the posted content or other information to be removed. Be advised, however, that applicable law may not permit us to completely or comprehensively remove your deleted content or for other reasons as set forth in this California law.
We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place.
BrandCycle does not share or transfer Personal Information that would constitute a “sale” under the California Consumer Privacy Act.
Registered publishers or retail partners can access and update their Personal Information from within their account.
Subject to applicable law, an individual has the right to request from us a copy of what Personal Information that we have collected or to ask to correct or update their it. Individuals can also request that we delete their Personal Information from our systems and records. We strive to respond to these requests with 30 days or as otherwise required by applicable law.
Whenever you directly provide us with your Personal Information, please be sure it is accurate and complete. We cannot be responsible for any information you provide to us that is incomplete or incorrect.
We will not collect, use, or disclose your Personal Information in any ways or for any purposes that are materially different from those set forth herein. However, if we wish to do so in the future, we will obtain your consent first, and offer you the choice to opt-out of such proposed collection, use, or disclosure.
If we send you promotional or marketing messages, you will be able to opt out of receiving our marketing or promotional email communications by using the “Unsubscribe” feature at the bottom of each email from us or by requesting to opt out by emailing us at email@example.com. We may also request that we not provide your information to our retail partners and/or publishers that we believe may be a good referral or revenue source for your business.
Please note that you cannot opt out of receiving transactional communications from us regarding services you request, your account with us or other transactional or administrative issues.
The Site is not intended for users under 16 years old. You must be at least 16 years old to register as a publisher and access our proprietary platform. If you are under 16, you should not access our Site, create an account, or provide any information to us.
We do not knowingly collect Personal Information from persons under 16 years of age. If you believe that we might have collected any Personal Information from a child under 16, please email us at firstname.lastname@example.org so we may remove it.
BrandCycle, Inc. Email: email@example.com | Address: 16 Rae Ave, Needham MA 02492