Bright and Quirky PLLC
Effective Date: 5/15/2020
This Policy applies to information we collect about you and/or your child (“you”) when you interact with us. This includes:
- When you access this Site or use our Services
- In email, text, and other electronic messages between you and this Site or our Services
- When you interact with our advertising and applications on third-party apps and services, if those applications or advertising include links to this policy, or
- When you participate in or attend an event hosted by us.
This Policy does not apply to information collected by any third party including through any application or content (such as advertising) that may link to or be accessible from or on the Site or Services.
We also include specific disclosures relating to California Resident Privacy Rights
Information We Collect and How We Collect It. We may collect the following information from you when you interact with the Site or our services:
- Personal Identifiers:
- We collect your name, phone number, and email address and contact address when you register for services or complete a transaction. If you choose to create a login account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile. We use this information to provide the Services, respond to your requests, and send information and advertisements to you.
- We use this information to provide the Services, respond to your requests, and send information and advertisements to you.
- We collect your social media handle and basic account information when you interact with our Services through social media.
- We collect a unique numerical identifier, assigned to you by a first-party cookie, automatically when you use our Services in order to identify you, provide the Services, keep you logged in to the Services, prevent fraud, and provide you with targeted information and offers.
- We may collect medical information and health information about you if you provide it to us when using or services. We use this information to respond to provide services, respond to your requests and address claims or complaints.
- We collect your IP address and device identifier (Device ID) automatically when you use our Services. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and serve targeted advertisements and offers based on your use of our Services or other online activities.
- Additional Personal Identifiers (sensitive): We currently use a third-party provider to process payments on our behalf. The third-party provider collects payment information when you provide it to us, which may include your credit card number or a bank account number, when you complete a transaction. We use this information to streamline and facilitate payments and transactions.
- Protected Classifications: We do not collect your racial or ethnic origin, or sexual orientation. We collect information about your gender and disability status if you provide that to us when using the Services or when requesting an accommodation or reporting a claim or incident.
- Commercial Information: When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies. We also collect payment information, such as payment method and transaction amounts. We use this information to processes your transactions, measure the effectiveness of our Services and provide you with targeted information, advertisements and offers.
- Biometric Information: We do not collect information about your physiological, biological, and behavioral characteristics.
- Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, information regarding your interaction with websites, and applications or advertisements automatically when you utilize our Services. We use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.
- Geolocation Data: As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on the IP address. We may also determine your precise location (e.g., your GPS coordinates) through your device. If you allow your device to provide us with this information, we use it to measure effectiveness and make improvements to our products, services, and advertising, provide recommendations and deliver relevant advertising and offers.
- Audio, electronic, visual, thermal, olfactory, or similar information:
- Video, audio, and/or electronic recordings of you may be collected when you participate in one of our live events. We may provide such recordings to other participants of our Services for their use and education.
- We collect records of your correspondence via email or any of our Services. We also collect electronic records of your correspondence with other participants through the Services. We use this information to improve our Services and respond to requests.
- We collect your responses to online surveys that we might ask you to complete for research purposes or to improve our offerings.
- If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We use this information to monitor our customer service, maintain the security of our systems and physical locations, and train employees.
- Professional or employment-related information: We collect information about your current employer and your employment history if you are an instructor/speaker or apply for a job with us. We use this information to promote our Services to others.
- Education information: We collect information about the institutions you have attended and the level of education you have attained if you are an instructor/speaker or apply for a job with us.. We use this information to promote our Services to others.
- Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We do not currently collect this type of information.
We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.
We also sell some information to third parties, as described below. To opt out of the sale of your information email us at firstname.lastname@example.org
Cookies, Web Beacons and Tracking Technologies
The technologies we use for automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual the web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. There are several types of cookies:
- Session Cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
- Persistent Cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
- First-Party Cookies are set by the site you are visiting.
- Third-Party Cookies are set by a third-party site separate from the site you are visiting.
- Flash Cookies. Flash cookies (also known as “Local Shared Objects” or “LSOs”) are different from browser cookies because of the amount and type of data that is stored, as well as the way in which data is stored. Flash cookies are commonly used for advertisements and videos.
- Web Beacons. Web beacons (also known as “pixel tags” “clear GIFs” and “single-pixel GIFs”) are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on a user’s computer hard drive or device, web beacons are embedded invisibly on web pages. We use beacons for similar reasons as cookies, though beacons primarily help us better manage content on our Site by informing us which content is effective (e.g. recording the popularity of certain pages on the Site or counting the users that have opened a particular email).
Controlling cookies. For browser-specific information on how to adjust cookie configurations on the following browsers, please click on the relevant link below:
- Internet Explorer [https://support.microsoft.com/en-us/help/278835/how-to-delete-cookie-files-in-internet-explorer]
- Firefox [https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies]
- Chrome [https://support.google.com/chrome/answer/95647?hl=en]
For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.
How We Use Information About You
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Site and its contents to you
- To provide our Services to participants
- To provide you with information, products or services that you request from us
- To fulfill any other purpose for which you provide the information
- To provide you with notices about your account, including expiration and renewal notices
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
- To notify you about changes to our Site or any products or services we offer or provide through the Site
- To allow you to participate in interactive features on our website
- To contact you about our own or third parties’ goods or services that may be of interest to you, if you have given your consent
- To display advertisements to our advertisers’ target audiences. Even though we do not disclose personal information about you for these purposes without your consent, if you click on or otherwise interact with an advertisement, then the advertiser may assume that you meet its target criteria
- In any other way we may describe when you provide the information
- For any other purpose compatible with the these purposes, or with your consent
Disclosure of Information About You
We may disclose aggregated information about our users and information that does not identify any individual without restriction.
- To our subsidiaries and affiliates (either now existing or thereby created in the future)
- To contractors, service providers and other vendors we use to support our business. These entities are by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- We use third parties to process and analyze data, and to enable targeted services and advertising.
- Google Analytics to process your data. Information about how Google uses your data can be found at: https://policies.google.com/privacy?hl=en
- We use integrations from Facebook. Information about how Facebook uses your data when you use our Site can be found at: https://www.facebook.com/policy.php
- We use third party data collector and processor ConvertKit to process your data to register for our mailing list. Information about how ConvertKit uses your data can be found at: https://convertkit.com/privacy/
- We use third party data collector and processor AccessAlly to process and record your payments. Information about how AccessAlly uses your data can be found at: https://accessally.com/privacy-policy/
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Site users is among the assets transferred.
- To third parties to market their products or services to you ;
- To fulfill the purpose for which you provide it
- For any other purpose disclosed by us when you provide the information
- With your consent
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request
- To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our Company, our customers or others.
Your Choices & Obligations
We may retain your personal data for a period of time consistent with the original purpose of collection. We determine the appropriate retention period for personal data on the basis of the amount, nature, and sensitivity of your personal data, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means, as well as the applicable legal requirements (such as applicable statutes of limitation).
We retain personal data about you while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Site and Services. Even if you only use our Site intermittently, we will retain your information and keep your account open until you decide to close your account.
Right to Access and Control Personal Data About You
For personal data that we have about you:
- Delete Data: You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to provide Services to you). If you request that any of your personal data be deleted, we reserve the right to terminate and/or limit your access to the Service to the extent Services cannot be reasonably provided without that information.
- Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data, particularly if it is inaccurate. Please contact us at the email address below.
- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data or to limit our use of it (e.g., if your personal data is inaccurate). We reserve the right to decline or modify our response to your request, e.g., when we have a legal right or legitimate business reason for doing so.
- Right to Access and/or Take Your Data: You can ask us for a copy personal data about you that you provided in machine readable form.
You can make requests by contacting us at: email@example.com.
California Resident Privacy Rights
Persons with disabilities may obtain this notice in alternative format upon request by contacting us at firstname.lastname@example.org.
California Shine the Light
Residents of the State of California have the right to request information from us regarding other companies to whom we have disclosed certain categories of information during the preceding year for those companies’ direct marketing purposes. At this time, we do not disclose information to other companies for their direct marketing purposes.
California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.
Right to Notice at Collection Regarding the Categories of Personal Information Collected
Right to Know/Access Information
You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may submit such a request as described below. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request.
Right to Request Deletion of Information
You have the right to request that we delete any Personal Information that we have collected directly from you, subject to some exceptions. You may submit such a request via email to email@example.com. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
In order to process your request to know/access or delete Personal Information we collect, disclose, or sell, we must verify your request. We do this by asking you to provide personal identifiers we can match against information we may have collected from you previously; and/or confirm your request using the email or telephone account stated in the request.
You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete declarations in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf.
Sale of Personal Information to Third Parties
We will not sell your Personal Information to third parties.
- Internet or Other Electronic Network Activity Information: We exchange your browsing history, search history, information regarding your interaction with websites, and applications or advertisements with our advertising and business partners.
To exercise your right to opt out of this use of your Personal Information, please contact us via email at firstname.lastname@example.org.
Please note that your right to opt out does not apply to our sharing of Personal Information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the Personal Information only for that function.
Special Information for Nevada Residents
Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. At this time, we do not engage in such sales.
If you choose to delete your account, we delete closed account information within 30 days of account closure, except as noted below.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.
We implement security safeguards designed to protect your data from loss, misuse, unauthorized access, disclosure and alteration. The security measures include firewalls, data encryption, and information access authorization controls. While we are dedicated to securing our Site and Services, you are responsible for securing and maintaining the privacy of your passwords and account registration information and verifying that the personal data we maintain about you is accurate and current.
Links to Other Websites
This Site is not directed to children under the age of 18. When we offer online Services intended for children under the age of 16, we obtain verifiable parental consent prior to interacting with or collecting personal data children. in compliance with the Children’s Online Privacy Protection Act. In such cases, we limit the information that we collect from children to what is reasonably necessary to provide the services and/or participate in the online activities. We do not disclose information collected from children under age 16 to third parties; however, if you or your child provides information while participating in one of our events, or through a chat or discussion forum, that information can be viewed by other participants. Parents may request access, correction or deletion of information collected from their children by contacting us at email@example.com.
Not a Healthcare Provider
We are not a healthcare provider or a covered entity, and are not subject to federal or state laws regulating privacy, security, or confidentiality of healthcare information, such as the Health Insurance Portability and Accountability Act (“HIPAA”).
Questions or Complaints