Privacy Policy

Effective Date: June 1, 2020

I. GENERAL

This Privacy Policy sets out how Brightfire (“Brightfire “, “we”, or “us”) uses and protects your Personal Information. This Privacy Notice applies to Personal Information collected by or on behalf of Brightfire and mobile versions of our websites (collectively “the Site”), by phone, text message, email or other communication mechanism, and anywhere else we display this privacy notice (collectively, the “Platforms”). Occasionally you may choose whether or not to provide or disclose Personal Information in connection with your use of the Platforms. If you choose not to provide the Personal Information we request, you may still visit and use parts of the Site, but may be unable to access or use certain features, options, programs, and services.  By using the Platforms, you accept and consent to the terms of our Terms of Use in effect at the time of your visit or use.

II. WHAT WE MEAN BY “PERSONAL INFORMATION”

For purposes of this Privacy Policy, “Personal Information” means information that directly or indirectly identifies you or can be used to identify you as an individual.

III. WHAT PERSONAL INFORMATION DO WE COLLECT?

(1)  Information Collected Automatically

Certain information is collected automatically on the Site by means of various software tools. We have a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of the Site. Alone or in combination with other information, such automatically collected information may constitute Personal Information. Some of our service providers (described in Section V, below) may use cookies or other methods to gather information regarding your use of the Site. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your use of the Site with any Personal Information about you that they may have. The use of such information by a third party depends on the privacy policy of that third party.

a) Log Files On The Site. The information inside the log files includes internet protocol (“IP”) addresses, type of browser, Internet Service Provider (“ISP”), date/time stamp, referring/exit pages, clicked pages and other information your browser may send to us about your use of the Site.

b) Cookies. We use cookies to make interactions with the Site easy and meaningful. When you visit the Site, our servers may send a cookie to your computer.

We may use cookies that are session-based and persistent. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your web browser’s ability to accept cookies, you will be able to navigate the Site, but you may not be able to use all of the features of the Site.

The following sets out how we may use different categories of cookies and your options for managing cookie settings:

The Site also uses Google Analytics. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Site, the IP address, and the type of operating system used in the devices used to access the Site. By using a browser plugin available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.

(2)  Information You Provide to Us

When you use the Site or otherwise communicate or interact with us through the Platforms, we collect information that you provide to us directly. For example, we collect information in the following circumstances: when you contact us via the Site; when you register for services and when you otherwise communicate with us through the Platforms.

The Personal Information you provide to us may include the following:

• Information you provide through our ‘Contact’ section, including your name, company, e-mail, phone number, and any other information you decide to provide;
• Information you provide via email or using the contact details listed on various parts of the Site, including your name, phone number, and any other information you provide to us;
• If you are one of our customers or suppliers, we may process limited Personal Information in the course of our business relation with you. Such Personal Information may include your name, company, title, e-mail address, telephone number and address.
• Other information: We may also collect any other information you may want to share with us. Moreover, if you contact us, a record of this correspondence may be kept.

(3)  Information Received from Third Parties

We may also obtain data from third-party sources such as our customers and vendors.

IV. PURPOSES FOR OUR COLLECTION AND USE OF PERSONAL INFORMATION

If you submit or we collect Personal Information through the Platforms, then such Personal Information may be used in the following ways: (i) to provide, analyze, administer, develop, and improve the Site or our services; (ii) to contact you in connection with the Site and notifications, services, , programs or offerings that you may have registered for; (iii) to send you updates and promotional materials that you have registered for; (iv) for our legitimate interests of documenting and managing our internal administration; and (v) to protect the rights and/or our property and to ensure the technical functionality and security of the Site.

With your consent (unless otherwise permitted by applicable law) we use the Personal Information you provide us to send you information on our products, services and other information based on the interests that you have indicated to us. You have the right to opt out of getting those messages. If you do not wish to receive these messages, click the unsubscribe link in your email. Please note that these selections are not permanent; they may be changed in the event you register for other products or services and consent to receive marketing messages. You may also email us at support@brightfire.net for assistance.

In addition to the above, we use your Personal Information in order to comply with applicable laws and for our legitimate purposes of protecting our legal rights, in connection with legal claims, and for compliance, regulatory, and investigative purposes. This may include sharing Personal Information with third parties, such as governmental authorities or law enforcement officials subject to applicable law.

V. WHO DO WE SHARE PERSONAL INFORMATION WITH?

We may disclose Personal Information you provide to us or that we collect automatically on the Site with the following categories of third parties:

• Service providers, such as data storage service providers, and communications service providers;
• Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
• Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Site and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Notice.

VI.THIRD PARTY PRACTICES

The Site may contain links to other sites, which are not owned or operated by Us or our affiliates. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply our endorsement of the linked site. Other sites may also reference or link to our Site. If you provide any Personal Information through a third-party website, your transaction will occur on such third party’s website (not our Site) and the Personal Information you provide will be collected by, and controlled by the privacy policy of, that third party. We are not responsible for the privacy practices or the content of such third-party websites, including such websites’ use of any Personal Information that you provide to them.

VII. INDIVIDUAL RIGHTS

Where we process Personal Information, individuals are entitled to ask us for an overview of the Personal Information we have about them and also to access, correct or delete certain Personal Information, restrict processing of their Personal Information, or to ask us to transfer some of Personal Information to other organizations. Certain individuals can also object to some processing of their Personal Information and, where we have asked for their consent, they can withdraw their consent at any time. Insofar as Personal Information about them is processed, certain individuals also have a right to know more about the protection we apply when transferring Personal Information to non-European Economic Area countries.

Note that we are not legally obligated to agree to such requests in all circumstances, and in certain circumstances, agreeing to a request may be infeasible – for example, a deletion request when we are required by law to maintain the Personal Information. Please also note that we are not able to act on any of the above requests if we are not in a position to identify an individual filing such request.

Where applicable, these rights can be exercised by sending us an email through the contact details further below. Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you.  We encourage you to first reach out to us at support@brightfire.net so we have an opportunity to address your concerns directly before you do so.

VIII. NOTICE TO CALIFORNIA RESIDENTS

The information in this section applies to residents of California. Please contact us at support@brightfire.net if you have any questions about this Privacy Policy, including this section specific to California residents, or if you would like a printed copy of this Privacy Notice. You may also print a copy of this Privacy Policy by selecting the “Print” button in your web browser.

(1)  How We Collect and Use Personal Information

In accordance with the California Consumer Privacy Act of 2018 (CCPA), this section describes the Personal Information we collected about California residents in the last 12 months, the sources of that information, our business or commercial purposes for collecting the information, and the third parties with whom we shared that information. Please refer to the corresponding sections of this policy above for details on the following:

• WHAT PERSONAL INFORMATION DO WE COLLECT: This section describes the categories of Personal Information we collected and the categories of sources from which the information was collected.
• PURPOSES FOR OUR COLLECTION AND USE OF PERSONAL INFORMATION: This section describes the business or commercial purposes for which we collected the information.
• WHO DO WE SHARE PERSONAL INFORMATION WITH: This section lists the categories of third parties with whom we shared Personal Information.

(2)  Your Rights and How to Exercise Them

Under the CCPA, California residents have certain rights with regards to their Personal Information. Those rights may only apply in certain circumstances and may be subject to limitations or exceptions. A summary of those rights is provided below as well as information on how to exercise your rights. Please note that we may require certain identifying information about you as necessary for us to verify your request in accordance with applicable law.

• Right to Know: You have the right to know the categories of Personal Information or specific pieces of Personal Information we collect, use, disclose and/or sell about you. To exercise this right, please email your request to support@brightfire.net.
• Right to Delete: You have the right to request us to delete the Personal Information we collect or maintain about you. To exercise this right, please email us at support@brightfire.net.  Please note that certain exceptions may apply to your right to delete information, such as when we must retain your information to comply with law. We will notify you if any such exceptions apply to your request.
• Right to Opt Out of Sale: You have the right to opt out or ask us not to sell your Personal Information. Please note that we do not sell your Personal Information.
• You can request that we delete your account and Personal Information by emailing your request to support@brightfire.net. Once your data is deleted, we are no longer able to match you to clinical trials.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for exercising any of your rights under the CCPA. However, we may offer certain financial incentives, charge reasonable fees related to your requests, or deny your right to know, right to opt out of sale or right to deletion in accordance with applicable law.

You can exercise these rights yourself or you can designate an authorized agent to make a request on your behalf. Your authorized agent must be able to demonstrate authority to act on your behalf as further instructed when submitting a verifiable request on your behalf. By submitting any of the requests described in this section, you are declaring that you are a California resident or an authorized representative or agent of a California resident, availing

XI.DATA RETENTION

We keep Personal Information for as long as it is needed to fulfill the purposes for which it was collected, to provide our services, to deal with possible legal claims, to comply with our business interests and/or to abide by all applicable laws. Thereafter, we either delete Personal Information about you or de-identify it. Please note that even if you request the deletion of Personal Information about you, we may be required (by law or otherwise) to retain the Personal Information and not delete it. However, once those requirements are removed, we will delete Personal Information about you in accordance with your request.

XII. DATA SECURITY

We follow generally accepted industry standards to protect the Personal Information we collect or process through the Platforms. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.

XIV.    CHILDREN

The Site is not intended for children under the age of 13. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 13 years of age. If we become aware that a child under age 13 has provided with Personal Information, we will delete such information from our files.

XVI. CHANGES TO THE PRIVACY POLICY

This Privacy Policy may change from time to time, effective from the date mentioned in the updated version of the Privacy Policy. Please check the Platforms periodically to review such changes in the Privacy Policy. We may email periodic reminders of our agreements and policies in the event of a material change.

XVII. CONTACT US

If you have any questions about this Privacy Policy or about our privacy or data security practices, please contact us via E-Mail at support@brightfire.net