For the purposes of data protection laws where applicable, BrilliantPad controls and processes Personal Information we hold about you.Where specific local laws require stricter standards than those prescribed in this Policy, BrilliantPad will process Consumer Data in accordance with applicable local law and may develop specific local policies in this regard.Where applicable local law provides a lower level of protection of Consumer Data than that established by this Policy, then the standard required by this Policy will apply.
TYPES OF DATA COLLECTED AND HOW WE USE IT
Among the types of Personal Information that this Service collects, includes personal contact information, purchase information, shipping information, cookies, usage data and technical information from the device, photographic data, and Email. We also collect information about your dog that you voluntarily provide to us.
The Personal Information may be freely provided by you (the “User”), or collected automatically when using our Service. This information includes your name, address(es), zip/postal code(s), credit card or banking information, for example;
BrilliantPad will collect your device information such as serial number, software version, and other technical information in order to provide updates and notifications, improve your experience over time, or troubleshoot problems with the device or Service;
On devices that are equipped with cameras, we will collect and process photographs taken by the device.This may include capturing and sending to you portions of this data as part of a notification or analyzing the data to identify motion or other events. If you instruct us by setting up your camera and choosing to receive mobile notifications, we may process information from your device to send you alerts when something happens.Events include animal presence, pad advance events, low or high usage alerts, low paper level in machine warnings, low roll count at home warnings, successful look-in request complete and device errors.
Users are free not to provide Personal Information, however, without it we may not be able to provide you with BrillliantPad products or full functionality of the products or services, through the Service.
We collect Personal Information from you, your device(s), and third parties that are registered with us based on legal bases and business purposes. More specifically, we use your Personal Information for the following purposes:
Help make the Site easier for you to use by not having to enter information more than once;
Help you quickly find information, products, and services;.
Help us create content that is most relevant to you;
Alert you to new information, products, and services that we offer;
Establish and maintain communications with you;
Where you have requested a product or service from BrilliantPad, assisting you in the completion of your application, the assessment of your eligibility for any such requested service, the processing and maintenance of the service, as well as any applicable renewal of such service;
Allow our affiliated companies to notify you of certain products or services offered by our affiliated companies;
Process transactions through service providers;
Meet legal, security, processing, and regulatory requirements;
Protect against fraud, suspicious activity, or other illegal activities; and
Compile statistics for analysis of our sites and our business.
We may combine information that we may collect from you from different means online as well as offline (or through mobile applications) into one customer profile, and use that information as described in this policy.
WE SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES
At Your Request:We may provide your Personal Information to third parties at your request.
Business Transfers:As we develop our business, we may buy or sell assets or business offerings. Customer information is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution or discussions regarding same.
Compliance with Laws and Law Enforcement:We may disclose your Personal Information if required to do so by law or subpoena or if we believe that it is reasonably necessary to comply with a law, regulation or legal process; to protect the safety of any business, person or member; to address fraud, security or technical issues; or to protect our rights or property or the rights of others. We may in our sole discretion elect in good faith to cooperate with any law enforcement agency requesting assistance with an official investigation by disclosing and/or sharing with such agency any and all information, data and/or content connected with you and/or your use of the Service. We may also, but need not, in our sole discretion, initiate a report to any law enforcement agency where it is reasonably suspected that unlawful activity may occur, or may have occurred, including but not limited to disclosing and/or sharing information, data and/or content connected with you and/or the Service.
We have agreements with third parties and service providers which provide that your information can only be used in connection with providing services for us, and that your personal data will be safeguarded with appropriate security measures.
We may also share information with others in an aggregated, deidentified, and anonymous form that does not reasonably identify you directly as an individual.
We may receive your information from third parties to the extent you link or use third party credentials to login to the Service.The third-party services will authenticate your identity and may share your Personal Information with us (such as your name, email address, and profile information). Similarly, we may receive certain Personal Information if you interact with our accounts on a social network, such as by “Liking” or “Following.” The data we receive from these third-party services is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Service.
We utilize Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google utilizes the Personal Information collected to track and examine the use of this Service, to prepare reports on its activities and share them with other Google services.
Google may use the Personal Information collected to contextualize and personalize the ads of its own advertising network.
Personal Information collected includes Cookie and Usage Data.
You can click here to opt out of the use of Google Analytics: Opt Out
DISPLAYING CONTENT FROM EXTERNAL PLATFORMSThese services allow you to view content hosted on external platforms directly from the pages of this Service and interact with them. If a service of this kind is installed, it may still collect web traffic data for the pages where the service is installed, even when users do not use it.
YouTube is a video content visualization service provided by Google that allows this Service to incorporate content of this kind on its pages.
The Personal Information collected includes Cookie and Usage Data.
INTERACTION WITH EXTERNAL SOCIAL NETWORKS AND PLATFORMSThese services allow interaction with social networks or other external platforms directly from the pages of this Service.
The interaction and information obtained by this Service are always subject to the User’s privacy settings for each social network.
If a service enabling interaction with social networks is installed it may still collect traffic data for the pages where the service is installed, even when Users do not use it.
Twitter Tweet Button and Social Widgets (Twitter)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter Inc.
The Personal Information collected includes Cookie and Usage Data.
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
The Personal Information collected includes Cookie and Usage Data.
We along with the third parties we engage, may collect certain types of usage information when you visit our Website or use our Apps, read our emails, or otherwise engage with us. We use this information to enhance and personalize your user experience, carry out interest based advertising and marketing, to monitor and improve our Website and Service, and for other internal purposes. In some instances, we and our third-party service providers may combine this usage information with Personal Information. If we do combine any usage information with Personal Information, the combined information will be treated by us as Personal Information.
If you would like to change the way we collect data about you in Twitter, visit Twitter account settings , Do Not Track browser setting, and the opt-out choices of Twitter’s ads. Please note that these changes will only change the way we collect and use Personal Information on Twitter, not on any other website or platform.
Our third-party advertising providers, including Google Analytics for Display Advertisers, also use these technologies for marketing on our behalf, including the delivery of interest-based ads and measurement of their performance.
You can also opt out of Google Analytics by installing Google’s opt-out browser add-on , and out of interest-based Google ads using Google’s Ads Settings . To opt out of activity-based ads in Facebook, visit your Facebook Ad Settings .
MANAGING EMAIL ADDRESSES AND SENDING MESSAGES
These services make it possible to manage a database of subscription based email contacts to communicate with the User via email. The services are used to collect data concerning the date and time when the mail is viewed by the User, as well as when the User interacts with incoming mail, such as by clicking on links included in the email.
You have the right to access, correct, and update your Personal Information.This can be done by accessing your Account on our Website, or within the app.Depending on your jurisdiction, you may be entitled to additional rights related to your Personal Information.
Requests to exercise your rights under applicable data privacy laws should be sent to us at firstname.lastname@example.org. This Service does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.
We use reasonable security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Information. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any of your Personal Information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.Please remember that you are responsible for maintaining the confidentiality and security of any member name and password you use in connection with the Service. If you believe that your account information is being used in an unauthorized fashion, you must contact us immediately.
The Service is intended for persons over the age of 16 years of age. We do not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to utilize the Service.If you become aware that Personal Information about a person under 16 has been provided to us, please immediately contact us using the details below.
TRANSFER AND STORAGE
This Service is operated from the United States. BrilliantPad may process your Personal Information outside the country you are located, where we and our third-party service providers have operations, including in the United States. If you are located outside of the United States, your information will be transferred to the United States for processing. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
BrilliantPad will retain Personal Information, or Personal Information related to consumer rights exercise requests for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with our users and provide the Services; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
We reserve the right to de-identify your personal data, including information about your device and Service usage, and to retain your anonymized/de-identified information for our own records.
YOUR PRIVACY RIGHTS IN CALIFORNIA
This California Privacy Notice (“California Notice”) applies to California residents whose Personal Information is processed by BrilliantPad pursuant to the California Consumer Privacy Act (“CCPA”) or other California privacy laws described below. The California Notice describes how we protect the Personal Information we process and control relating to California residents and rights California residents may have in relation to this Personal Information. For purposes of this California Notice, “Personal Information” has the meaning provided by the CCPA and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with you, or that is excluded from the CCPA’s scope.
Your California Rights and Choices: As a California resident, you may be able to request to exercise the following rights:
The Right to Know any or all of the following information relating to your Personal Information we have collected and disclosed in the last 12 months, upon verification of your identity:
The specific pieces of Personal Information we have collected about you;
The categories of Personal Information we have collected about you;
The categories of sources of the Personal Information;
The categories of Personal Information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
The categories of Personal Information we have sold and the categories of third parties to whom the information was sold; and
The business or commercial purposes for collecting or selling the Personal Information.
The Right to Request Deletion of Personal Information we have collected from you. However, this right is limited by a number of exceptions. Fundamentally, if BrilliantPad has a permissible need to retain Personal Information, we are not under an obligation to delete such information, even when requested. Generally, we retain Personal Information so we may complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality of our online properties; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with BrilliantPad; comply with a legal obligation; or otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which your provided the information. As such, we generally do not accept requests to delete Personal Information.
The Right to Opt Out of Personal Information Sales to third parties now or in the future.
What We Do:While we collect, process, and share your information for purposes described in this policy, which include “business purposes” under the CCPA,we do not currently “sell” Personal Information as most people would typically understand that term. However, we do allow certain third-party advertising partners to collect information about the users of our Service for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting. The CCPA considers this kind of transfer of your Personal Information a “sale”. You have the right to opt out of the “sale” of your Personal Information.Such requests may be submitted by following the “Do Not Sell My Personal Information” link at the bottom of the page, or in the settings menu in the App.To learn more about online advertising and how you may be able to control some of this activity, please refer to the “Cookies” and “Advertising” sections above.
You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process Personal Information. For example, if you submit a deletion request, we may no longer be able to provide you our products and services or engage with you in the same manner.
To submit your California Consumer Rights Requests: You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional Personal Information from you or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.
To exercise your California Consumer Rights to Know or Delete, or for additional information, please submit a request to email@example.com, or call us at (800) 555-1212
You may also submit a verifiable consumer request through an authorized agent.To do so please be prepared for your agent to provide a signed permission to do so, to verify their own identity with us, and to directly confirm with us that you provided the agent permission to submit the request.
California’s “Shine the Light” Law . California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of Personal Information to third parties for their direct marketing purposes. To opt-out of having your Personal Information disclosed to third parties for their direct marketing purposes, please submit a request using one of the California consumer rights request methods designated above.