Effective Date: February 1, 2019
BrightGuest participates in the Privacy Shield, and can be found included in the list of all participating companies at https://www.privacyshield.gov/list.
BrightGuest is commitment to the Privacy Shield principles about all personal data received from the EU in reliance on the Privacy Shield.
There is an independent dispute resolution body designated to address data privacy complaints and provide appropriate recourse free of charge to the individual, and whether it is: (1) the panel established by DPAs, (2) an alternative dispute resolution provider based in the EU, or (3) an alternative dispute resolution provider based in the United States.
As with any company having access to your data, BrightGuest is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
You have the possibility, under certain conditions, to invoke binding arbitration.
BrightGuest is subject to the requirement to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and the potential liability in cases of onward transfers to third parties.
Privacy Shield – Independent recourse mechanism
In compliance with the Privacy Shield Principles, BrightGuest commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact BrightGuest at: email@example.com or (888) 978-6235.
BrightGuest has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.
Privacy Shield – Data collection opt-out
BrightGuest offer individuals the opportunity to choose (opt-out) whether their personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. Each individual using BrightGuest is provided with clear, conspicuous, and readily available mechanisms to exercise choice by providing an opportunity to opt-out of having their data collected.
The Information We Collect About You
We collect information about you directly from you and from third parties, as well as automatically through your use of our Site or Services.
Information We Collect Directly From You.
Certain areas and features of our Site and Services require registration. To register you must provide your name, organization and email address. We also may collect additional optional information from you; however, you are not required to provide us with this information. In addition, if you make a purchase, we will also request that you provide your credit or debit card information and your billing address.
Information We Collect Automatically.
We may automatically collect the following information about your use of our Site or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site and or use our Services; and the referring URL, or the webpage that led you to our Site, and the following: access time, browser type, device ID, domain name, IP address, page views and referring URL. We may combine this information with other information that we have collected about you, including, where applicable, your name, and other personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
- To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
- To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site or our Services.
- For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you newsletters, special offers, and promotions, or to otherwise contact you about information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Services on third party websites.
- To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.
- To administer our customer loyalty program.
- To build a profile of user interests.
How We Share Your Information
We may share your information, including personal information, as follows:
- BrightGuest Customers. Our Services are designed to enable our customers to engage with users through targeted marketing. Therefore, information collected through our Services is shared with such customers and is handled by such customers under the terms of their privacy policies. You should review such privacy policies before sharing your information with such third parties (see “Third Party Links” below).
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
- Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which BrightGuest is involved.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Services.
- Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, to track users activities and to display advertising from our customers and partners both on our Site and on third-party sites. In addition, our ad management partners and customers may provide us persistent cookies and other technologies which we can use to determine which advertisements bring users to their websites and mobile application. The unique cookie, if it exists on your computer, was placed there either by us or by another advertiser who works with our ad management partners. The information that we collect and share through the use of these technologies is anonymous and is used only to study advertising trends and effectiveness.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Third Party Analytics.
Third-Party Ad Networks
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA).
Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.
User Generated Content
All content and information you post to our Site and Services, including, but not limited to your comments, images, videos and any other information will be available to all recipients you contact with a link to view such content. If you post your own content on our Site or Services, your posting may become public and BrightGuest cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.
Our Site and Services may be used by third party advertisers and may contain links to third-party websites. Any access to and use of such Services by said third parties and linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third parties or third party websites. We are not responsible for the information practices of such third parties or third party websites.
Security of My Personal Information
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access To My Personal Information
You may modify personal information that you have submitted by logging into your account and updating your profile information.
What Choices Do I Have Regarding Use of My Personal Information?
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
Children Under 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
Special Information for California Consumers
California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at: Please allow up to thirty (30) days for a response.
If you have questions about the privacy aspects of our Site or Services or would like to make a complaint, please contact us at firstname.lastname@example.org or (888) 978-6235.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site, at https://www.brightguest.com/privacy-policy/. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site, or notifying the Customer by the email address affiliated with Customer’s account.