Brillium Privacy Statement
Brillium, Inc. respects the privacy of our customers, business partners, employees, job applicants, and other visitors to our website (www.brillium.com) and our Brillium Software Platform (“Brillium”) located on various brillium.com servers under the WebsiteName.brillium.com website addresses who may choose to provide us with their personal information. The use of information collected through our service shall be limited to the purpose of providing the service for which the Client has engaged Brillium, Inc.
We recognize the need for appropriate protections and management of personal information that you provide to us. This Privacy Statement will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared.
EU-U.S. Privacy Shield
Brillium, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Brillium, Inc. is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]
Brillium, Inc. is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Brillium, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Brillium, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Brillium, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
U.S. – Swiss Safe Harbor Framework
Brillium, Inc. complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. Brillium, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Brillium, Inc.’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
Information Collection and Use – Brillium Service Platform
Service Provider Collection/Use
Brillium, Inc. collects information under the direction of its Clients on its Brillium Platform, Brillium, Inc. has no direct relationship with the individuals whose personal data it processes. Brillium works with its Clients to help them provide notice to their customers concerning, the purpose for which personal information is collected.
We collect the following kinds of personal information from our Clients:
- Contact Information such as name, email address, mailing address, phone number
- Unique Identifiers such as user name and password
We also collect the following information from our Clients:
- Information about your business such as company name, company size, business type
- Assessment information
- Training Information
- Internet locations and/or links to external files, images, videos or other content
We use this information to:
- Process Exams and Assessments
- Send you requested product or service information
- Respond to customer service requests
- Administer your account, including billing and payment information
- Send you service maintenance notifications
- Send you a newsletter
- Send you marketing communications
We collect information for our Clients, if you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the client that you interact with directly. If you are a Client and would like to update your account please contact us here or by emailing us at: support at brillium dot com.
Service Provider, Sub-Processors/Onward Transfer
Brillium, Inc. may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients.
Access to Data Controlled by our Clients
Brillium, Inc. acknowledges that you have the right to access your personal information. Brillium, Inc. has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Brillium, Inc. Client (the data controller). If the client requests Brillium, Inc. to remove the data, Brillium, Inc. will respond to their Client’s request within 30 business days.
Information We Collect on our Website
Personal Information is information that can be used to identify or contact a specific individual, such as a name, address, telephone number or email address. Brillium, Inc. may collect certain personal information from customers, business partners, and employees when signing up for our forum, requesting information, contacting support, or signing up for our newsletter. Brillium, Inc. does not collect personal information when you visit Brillium’s websites unless you choose to provide such personal information.
Customers and Partners: On Brillium, Inc. websites you can, register products, request information, subscribe to marketing or support materials, register to a secure extranet site to obtain access to product information, support, services and training. The types of personal information you provide to us on these pages may include name, address, phone number, fax number, e-mail address, user IDs and passwords, billing, and contact preferences.
How Personal Information is Used?
Brillium, Inc. will use personal information to provide customers and business partners with information and services and to help us better understand your needs and interests. Specifically, we use your information to help you complete creating your account for our forum, to communicate with you, to send you newsletters or marketing emails, provide you with information you requested and to provide ongoing service and support. Occasionally we may use your information to contact you to complete surveys that we use for marketing and quality assurance purposes. Personal information collected online may be combined with information you provide to Brillium, Inc. through other sources such as trade shows or seminars.
However, if you request information on any of our products/services, Brillium may provide your information to third party distributors and resellers who may subsequently contact you directly to purchase such products/services. In these instances, you will not have the opportunity to opt out of having your information shared with these third party distributors and resellers.
If you wish to subscribe to our newsletter(s), we will use your email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe. Please see the “Choice and Opt-out” section.
Some of Brillium, Inc. websites use on-line chat forums and blogs that are made available to our website and service users. You should be aware that any personal information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
When using the forum on our site you are able to create a public profile, the information that you are able to provide is instant messenger user names, email address, location, occupation and interests. As stated above we are not responsible for the personal information you submit within this area. Except as provided in this Statement, Brillium, Inc. does not use your personal information for a purpose other than the stated purpose for which such information is collected.
Personal information given to Brillium, Inc. may be transferred within Brillium, Inc. across state and country borders for efficient data consolidation, storage and simplified information management.
Who Does Brillium Share Personal Information With?
Brillium, Inc. may contract with third party service providers and suppliers, such as web hosting companies, or other service organizations required to perform requested services, etc., to deliver partial or complete products, services and solutions for our customers. Brillium, Inc. may share personal information with its service providers and suppliers for the sole purpose and only to the extent needed to support the customers’ business needs. Service providers and suppliers are required to keep confidential the personal information received from Brillium, Inc. and may not use it for any purpose other than as originally intended.
Third party vendors, service providers and suppliers receiving personal information are expected to apply the same level of privacy protection as contained in this Privacy Statement.
In certain situations, Brillium, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website. If Brillium, Inc. is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Choice and Consent
Brillium, Inc. does not require customers, business partners or non-employee visitors to Brillium, Inc. websites to provide Brillium, Inc. with personal information. The decision to provide personal information is voluntary. If you do not wish to provide the personal information requested, however, you may not be able to proceed with particular activities or receive the full benefit for which the personal information is being requested.
If you no longer wish to receive our newsletter, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at email@example.com or by sending your opt-out notification to Brillium, Inc. 101 Marketplace Ave. Ste 404-405 Ponte Vedra, FL 32081.
Brillium, Inc. makes efforts to keep your personal information accurate. We have implemented technology, processes and policies to maintain data accuracy and integrity. We will provide you with access to your information, and in some cases may make reasonable efforts to provide you with online access and the opportunity to change or delete any inaccuracies within your information. To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access to your data. If you have a forum account you may correct or delete any inaccuracies within your information by logging into your account. Otherwise you may email us at firstname.lastname@example.org. We will respond to your request to access within 30 days.
Brillium, Inc. will not process personal information in a way that is incompatible with the purposes for which it has been collected or authorized by the individual, or as required by applicable law.
Upon request Brillium, Inc. will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at email@example.com.
Brillium, Inc. is committed to making reasonable efforts to secure the personal data you choose to provide us. To protect the privacy of any personal information you or our clients may have provided to us, we employ reasonable industry-standard controls including physical and logical access controls, network security devices, and anti-virus protection. When you enter sensitive information (such as login credentials) we encrypt the transmission of that information using secure socket layer technology (SSL). If you have any questions about security on our website, Brillium Platform, you can email us at firstname.lastname@example.org.
Brillium will retain personal data we process on behalf of our Clients and data collected on our websites for as long as needed to provide services to our Client and other website users. Brillium will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Log Files – As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.
Links to Non-Brillium Websites and Third Parties
The Brillium, Inc. websites may provide links to third-party websites for your convenience and information. If you access those links, you will leave the Brillium, Inc. website. Brillium, Inc. does not control those sites or their privacy practices, which may differ from our own. We do not endorse or make any representations about third party websites. The personal data you choose to give to unrelated third parties is not covered by the Brillium, Inc. Privacy Statement. We encourage you to review the privacy statement of any company or website before submitting your personal information. Some third party companies may choose to share their personal data with Brillium, Inc. ; that sharing is governed by that third party company’s privacy statement.
If you choose to use our invitation service to tell a friend about assessments you have created through our software and services, we will ask you for your friend’s name and email address in addition to other information you may choose to store about your friend on our software and services. On behalf of you, we will send your friend one or more emails, inviting him or her to visit the site and complete your assessment. Brillium, Inc. stores this information for the sole purpose of sending these emails, tracking the success of your assessment and our invitation service and providing you with the services we offer you.
You may remove your friend from our software and services using the controls we provide you through the software and services provided to you for your use. Alternatively, your friend may contact us at email@example.com to request that we remove this information from your database.
Social Media Widgets
You can log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.
Third Party E-Commerce
Our shopping cart is hosted by our e-commerce solutions provider. They host our ordering system, and collect your billing information directly from you for the purpose of processing your order. This company does not use this information for any other purpose.
Brillium, Inc. will engage in periodic self-assessment to verify that it continues to be in compliance with this Privacy Statement. Contact Information
If you have any questions regarding this Privacy Statement or believe that the privacy of your personal information has not been respected, you may make a written submission to the attention of Brillium, Inc. Legal Administration Office, 101 Marketplace Ave. Ste 404-405 Ponte Vedra, FL 32081.
Except as provided above, dispute resolution for all other individuals shall be in accordance with applicable law.
Changes to this Statement
If we decide to change our privacy statement, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this statement, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective.
Revised: September 20, 2016