Privacy Policy

BRIGHTSWIPE PRIVACY POLICY

Date of last revision: December 20, 2022

1. Introduction

Welcome to Brightswipe’s Privacy Policy. Thank you for taking the time to read it.

This Privacy Policy describes the information Brightswipe, Inc. (“Brightswipe”) collects, why we collect it, how it is used, and your choices regarding your information. It applicable to our practices on our iOS and Android mobile applications, our website at www.brightswipe.com, and any other platform we control that links to this Privacy Policy, which applications, website, and platforms we may for convenience refer to collectively as the “App.”

2. Information Collection Practices
3. TYPES OF INFORMATION COLLECTED

Personal Information Collected In order for you to access and purchase services offered via the App (the “Services”), we may require you to provide personal information that identifies you (“Personal Information”). Personal Information may include the following: 

• Contact data: such as your name, phone number, and email address (“Contact Data”);
• Financial data: such as your account number, purchases, and billing or payment processing information (“Financial Data”); and
• Demographic data: such as your zip code and age (“Demographic Data”) 

Additionally, if you communicate with us by email or complete online forms or surveys, any information you provide may be collected as Personal Information.

Traffic Data Collected We may automatically track and collect certain categories of information when you access the App. We refer to these categories of information as “Traffic Data. ” Traffic Data may include:

• Internet Protocol (“IP”) address;
• access time;
• browser type;
• Internet Service Provider (“ISP”);
• the pages, features, or content you visit on the App; 
• the URL of the page that referred you to the App;
• domain servers;
• types of devices accessing the App;
• with respect to your device, its type of operating system and associated user identification information.

1. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels, Software Developers Kits (SDKs)) to recognize you and/or your device(s).

Cookies Cookies are small text files that are sent to or accessed from your web browser or your device’s memory. A cookie typically contains the name of the domain (Internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your device, such as user settings, browsing history, and/or activities conducted while using our Services.

Other tracking technologies Other technologies, such as web beacons (also called pixel, tags or clear gifs), tracking URLs, and SDKs are used for similar purposes as cookies. Web beacons are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our service or opened an email that we have sent them. Tracking URLs are custom generated links that help us understand where the traffic to our web pages originates. SDKs are small pieces of code included in apps which function like cookies and web beacons.

For convenience, this Privacy Policy, unless the context indicates otherwise, will also refer to these other tracking technologies as “cookies.”

What we use cookies for We use cookies for different purposes. These include to:

• Understand App traffic patterns;
• Recognize you and how you use and interact with the App;
• Remember your preferences;
• Improve and secure Brightswipe Services;
• Measure the success of our marketing campaigns;
• Provide anonymous individual or aggregated auditing, modeling, and reporting for our advertisers and other partners; and,
• Personalize and tailor ads to your interests.

Please note that cookies may be placed by a third party service provider who performs these functions for us. These third parties may have their own privacy policies.

When you use our Services, some, or all of the following types of cookies may be set on your device.

Cookie type	Description
Essential cookies	These cookies are strictly necessary to provide our Services, such as enabling you to log in, remembering your preferences, and keeping you safe by detecting malicious activity.
Analytics cookies	These cookies help us understand how our Services are being used and help us customize and improve our Services for you.
Advertising & marketing cookies	These cookies are used to determine how effective our marketing campaigns are and make the ads you see more relevant to you. They perform functions like helping us understand how much traffic our marketing campaigns drive on our Services, preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements relevant to you and measuring the number of ads displayed and their performance, such as how many people interacted with a given ad.

 

How you can control cookies There are several cookie management options. Please note that changes you make to your cookie preferences may make using our Services a less satisfying experience as they may not be as personalized to you. In some cases, you may even find yourself unable to use all or part of our Services.

Tools we provide You can set and adjust your cookies preferences at any time, by using the tool available on our website www.brightswipe.com. 

Browser and devices controls Some web browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer. The procedure for managing cookies is slightly different for each Internet browser. You can check the specific steps in your particular browser help menu.

You also may be able to reset device identifiers or opt out from having identifiers collected or processed by using the appropriate setting on your mobile device. The procedures for managing identifiers are slightly different for each device. You can check the specific steps in the help or settings menu of your particular device.

Google Analytics We use Google Analytics, which is a Google service that uses cookies and other data collection technologies to collect information about your use of the website and Services in order to report trends. For more information on how Google collects and processes data, visit https://policies.google.com/technologies/partner-sites. You can opt out of Google Analytics by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout, and opt out of Google’s ad personalization at https://adssettings.google.com/.

“Do Not Track” features Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option, and DNT signals are not yet uniform. For this reason, many businesses, including Brightswipe, do not currently respond to DNT signals.

1. USE OF INFORMATION COLLECTED

Brightswipe uses the information we collect through the App and data collection technologies to provide and improve our Services, to help keep you safe, and to provide advertising that may be of interest to you. These uses include:

• To administer your account and provide Services to you

• Enable you to access and use the App
• Process and complete transactions you request, and send related information such as purchase confirmations
• Respond to your questions and requests and provide customer support
• Send you notices, updates, and security alerts

• To operate advertising and marketing campaigns

• Monitor and analyze App and Services usage, activities, and trends for marketing or advertising purposes
• Perform and measure the effectiveness of advertising campaigns on our Services and marketing campaigns promoting Brightswipe Services

• To improve our Services and develop new ones

• Understand how our users typically use the Services to improve service utility
• Administer market studies
• Develop new features and services

• To detect and counter fraud and other illegal or unauthorized activities

• Investigate and address suspicious or fraudulent transactions or illegal activities
• Find and address ongoing, suspected, or alleged violations of our Terms of Use [https://brightswipe.com/app-terms-of-use/] 
• Better understand and design countermeasures against violations of our Terms of Use [https://brightswipe.com/app-terms-of-use/]
• Retain data related to violations of our Terms of Use [https://brightswipe.com/app-terms-of-use/] to prevent reoccurrences
• Enforce or exercise our rights, for example, under our Terms of Use [https://brightswipe.com/app-terms-of-use/]

• To ensure legal compliance

• Comply with legal requirements
• Assist law enforcement

1. LEGAL BASES FOR PROCESSING OF YOUR INFORMATION

To process your information as described in this Privacy Policy, we rely on the following legal bases:

• Provide Service to you The reason we process your information for purpose C.i., above, is to perform the contract that you have with us. For example, as you use our Service, we use your information to maintain your account and provide our paid features to you as well as other App users.
• Legitimate interests We process your information for purposes C.ii., C.iii., and C.iv., above, based on our legitimate interest. For instance, we analyze users’ behavior on our Services to improve our offerings and promote our Services. We process information to help keep our App users safe and we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.
• Comply with applicable laws and regulations We process your information for purpose C.v., above, where it is necessary for us to comply with applicable laws and regulations or evidence our compliance with applicable laws and regulations. For instance, we retain traffic data and data about transactions in line with our accounting, tax, and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement. We also keep data evidencing consents members give us and decisions they may have taken to opt out of a given feature or processing.

1. SHARING OF PERSONAL INFORMATION

We may share Personal Information with advertisers. However, we do not share your Financial Data with advertisers. We may share Financial Data with our business service providers who assist us to verify your qualifications for certain Services and to bill you for services. Those business service providers agree to uphold the same standards of security and confidentiality described in this Privacy Policy, and they will only use your Financial Data to carry out their specific business obligations to Brightswipe. 

If you do not want us to share your Personal Information with advertisers, please email us at support@brightswipe.com. We also maintain a procedure for you to request changes to your Personal Information or deactivate and delete your account. 

1. INTERNET BASED ADS

We may also share Traffic Data with advertisers and other third parties who may use it for advertising purposes, including to serve targeted advertising on third party sites. These companies may utilize cookies, pixels, or other technologies to collect user information (e.g., hashed/de-identified data, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, etc.) during your use of the App in order to provide advertisements about goods and services likely to be of greater interest to you. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information about your online activities on the App or other websites over time. For example, anonymous information collected across multiple sites may enable the ad network to predict your preferences and show you ads that are likely to be of interest to you. You may also visit http://www.aboutads.info/choices/ to learn about interest based advertising and how to opt out from online behavioral ads served by some or all participating companies.

1. OTHER DISCLOSURES If we or some or all of our assets are acquired by another company, including through a sale in connection with a bankruptcy, that company will possess the information collected by us, and it will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy. We may disclose Personal Information or other data to comply with law or legal requirements, enforce or apply our Terms of Use and other agreements, or protect our rights, property, the safety of our users or others.
2. EMAIL MARKETING

By submitting your email address via the App, you are expressly consenting to receive emails from Brightswipe and/or from third parties concerning offers and advertisements unrelated to Brightswipe. To unsubscribe from receiving email messages from us or from other third parties, click on the “Unsubscribe” link contained in each email. 

3. Confidentiality and Security of Personal Information
4. USER ABILITY TO UPDATE PERSONAL INFORMATION OR DEACTIVATE ACCOUNT

At any time a Brightswipe account holder may contact Brightswipe via email at support@brightswipe.com to update your Personal Information, request that your Personal Information no longer be shared by Brightswipe with third parties other than our service providers, or to delete your Brightswipe account.

You also have the ability to initiate the deletion of your Brightswipe account from within the App under “Account,” “Delete Account”, or you may email us at support@brightswipe.com, but note that we may retain certain information as required by law or for other legitimate business purposes. We may also maintain archived copies of your information. We will otherwise retain your information as needed to provide you services and to process your information as requested by you. We will retain and use your information to comply with our legal obligations, resolve disputes, and enforce our agreements. 

1. SECURITY

Brightswipe uses reasonable security measures to protect against the loss, misuse, and alteration of the information under the control of Brightswipe.

4. Public Information

The App and Services may contain links to websites not operated by Brightswipe. We are not responsible for the privacy practices or the content of such websites. Please review the privacy policies of each site you visit.

5. Updates and Changes to Privacy Policy

We may change this Privacy Policy, in whole or in part, at any time. Posting of the updated Privacy Policy on the App and at https://brightswipe.com/app-privacy-policy/ will constitute notice to you of any such changes, although we may choose other types of notice for certain changes. Changes will become effective upon notice. Your continued use of the App shall constitute your acceptance of all changes, and each use of the App or Services constitutes your reaffirmation of your acceptance of this Privacy Policy.

If you have questions about this Privacy Policy or want to contact us, please send an email to support@brightswipe.com, call Customer Support at (888) 794-7360, or write to us at:

Brightswipe, Inc.
Attn. Customer Support
1451 W. Cypress Creek Road, Suite 300
Fort Lauderdale, FL 33309