Updated: January 6, 2022
Collection of Personal Information
Personal Information You Provide to Us
We may collect information you provide to us. The types of information we may collect directly from you include your name, username, email address, postal address, phone number, information about your data storage preferences, employer’s name, job title, transactional information (including services purchased or subscribed to and billing address) as well as any contact or other information you choose to provide.
Automatic Collection of Personal Information
We collect personal information automatically when you use the BRT Service. When you access or use the BRT Service, we may automatically collect information about you, including but not limited to:
- Usage Information: We monitor user activity in connection with the BRT Services and may collect information about the applications and features you use, the websites you visit, the sizes and names of the files or folders you upload, download, share or access while using the BRT Services, the content you access and any actions taken in connection with the access and use of your content in the BRT Services.
- Log Information: We log information about you when you access and use the BRT Services including your Internet Protocol (“IP”) address, access times, browser type and language, Internet Service Provider (“ISP”), the Web pages that you visit, the content you use and the URL of the Web page you visited before navigating to the BRT Services.
- Device Information: If you access the BRT Services from a mobile device, we collect information about the device, including the hardware model, operating system and version, unique device identifiers, mobile network information (as allowed by the mobile network) or platform information (as allowed by the specific platform type). We do not ask for, access or track any location based information from your mobile device at any time while downloading or using our mobile apps.
- Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, which may include saving cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the BRT Services and your experience, customize your experience and preferences, allow you to access and use the BRT Services without re-entering your member ID and/or password, understand which areas and features of the BRT Services are most popular, deliver advertising and other content that may be of interest to you, count visits, and other purposes. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images (also called “gifs”) that may be used in the BRT Services or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness, determine whether an email has been opened and acted upon, and other purposes. For more information about cookies and how to disable them, please see “Your Choices” below. We, our service providers, and our advertising partners also may use these technologies to collect information about your online activities over time on our sites and services and across third-party websites or other online services (behavioral tracking). We do not respond to browser-based “do not track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Personal Information Collected from Other Sources
We may also obtain personal information about you from third parties and combine that with information we collect through the BRT Services and other means. For example, we may have access to certain information from a third-party platform or social media service if you create or log into your online account through the service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party platform or social media service is in accordance with the authorization procedures determined by the relevant platform or social media service. We may also receive information about you from your employer or other sources, such as our business partners or from individuals who refer you to us. We may also receive information about you from third parties, including marketers and advertisers. We may add this information to other information we collect from you.
Use of Personal Information
To Provide Our Products and Services
We may use your personal information:
- To operate and improve the BRT Services and our business;
- To confirm that you are an actual person and not a bot;
- To facilitate the creation and maintenance of and secure your account on our network and identify you as a user in our system;
- To respond to any questions or concerns that you may have, and to respond to your inquiries and support tickets;
- To provide you with the products, services, information, and transactions that you request; and
- To better understand your needs and provide you with more personalized services.
We may send you marketing, promotional communications, upgrades and special offers related to our services and for other marketing purposes of ours or our third party companies. You may opt-out of our marketing communications as described in the “Your Choices” section, below.
Research and Development
We may use your personal information for research and development purposes, such as for market research, analytical purposes, project planning, and product development; to improve the Service; to understand and analyze the usage trends and preferences of our users; and to develop new features, functionality, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We use and share such aggregated, anonymous data for any legal business purpose.
Compliance, Fraud Prevention, and Safety
We may use your personal information for compliance, fraud prevention, and safety purposes, such as troubleshooting problems; detecting and protecting against errors, fraud, or other criminal activity; maintaining the safety, security, and integrity of the BRT Services, products and services, business, databases and other technology assets; protecting our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); auditing our internal processes for compliance with legal and contractual requirements and internal policies; enforcing the terms and conditions that govern the BRT Services and our other product and service offerings; and preventing, identifying, investigating and deterring fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. We will also use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities, and to fulfill other legitimate purposes permitted by applicable law.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name.
Sharing and Disclosure of Personal Information
- Vendors, Consultants and Other Service Providers: We may share your information with third-party vendors, consultants and other service providers who are working on our behalf and require access to your information to carry out that work, such as billing, customer support, website hosting, maintenance, database management, cloud storage, document signature and management, web analytics, email software, CRM software, payment processing, marketing, and other purposes.
- Corporate Account: If you are an individual registered user of the BRT Service and the domain of the primary email address associated with your BRT Service account is owned by your employer and was assigned to you as an employee of that organization, and such organization wishes to establish a BRT Service corporate account, then certain information concerning past use of your individual account may become accessible to that organization’s administrator including your email address.
- For Collaboration: We may share your information, including when you choose to use collaboration features in the BRT Services that by their nature support sharing with third parties who you choose. Your name, email address, information from your profile and online account, and any content you choose to share will be shared with such third parties, and such third parties may communicate with you (such as by posting comments or emailing you) in connection with your use of the collaboration features of the BRT Services. You can choose to change your settings at any time as provided through your account. For more information about such collaboration and sharing features, we encourage you to review the information provided at https://support.dynafile.com/sharing-documents.
- Compliance with Laws: We may disclose your information to law enforcement, government authorities, and other relevant third parties if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements and policies, (c) to protect the security or integrity of the BRT Services, (d) to protect BRT, our customers or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to carry out the purposes described in the section above titled “Compliance, Fraud Prevention, and Safety”.
- Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any business transaction (or potential transaction) involving a merger, sale of company assets, financing, acquisition of all or a portion of our business to another company, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings)..
- Marketing Communications: We may share your information with our affiliated businesses, partners, and agents so that they may communicate to our customers, respond to visitors’ e-mails, or to inform you about events or new products.
- Related Companies: We may share personal information about you with any of our subsidiaries, affiliates, and other related companies.
- Advertising Partners: We may also share personal information about you with third parties who we partner with for advertising campaigns, special events and offers, or other activities in connection with the BRT Services, or that collect information about your activity on the BRT Services and other online sites and services to help us advertise our products and service. Some of these partners may also use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms.
- Professional Advisors: We may share your personal information with persons, companies, or professional firms providing us with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.
International Data Transfer
BRT is based, and this website is hosted, in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law, please note that your personal information may be transferred to the United States of America. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any terms and conditions related to the use of and access to the website.
With respect to BRT’s obligations as a processor under data protection laws in the European Economic Area, the United Kingdom, or Switzerland, BRT relies on mechanism approved under European data protection law, such as the Standard Contractual Clauses, as the basis for BRT’s approach to global data privacy protection. If you or your organization is required under the GDPR to enter into a contract or other binding legal act under EU or Member State law with your data processors, and BRT is acting as a processor for you, as the controller, as those terms are defined by GDPR, you may request that BRT enter into a Data Processing Addendum with Standard Contractual Clauses by contacting us at [email protected].
EU-U.S. and Swiss-U.S. Privacy Shield Framework
In compliance with the Privacy Shield Principles, BRT commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact BRT at:
Blue Ribbon Technologies, LLC
Attn: Privacy Department
6030 Greenwood Plaza Blvd, Suite 110
Greenwood Village, CO 80111
BRT has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
BRT has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Program to an independent dispute resolution mechanism, the American Arbitration Association (ICDR®-AAA® EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Program). If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by BRT, please contact the EU or Swiss DPAs or the American Arbitration Association at http://go.adr.org/privacyshield.html, whichever applies, for more information and to file a complaint. A binding arbitration option is available to you in order to address residual complaints not resolved by any other means. The services of the EU or Swiss DPAs and the ICDR/AAA Privacy Shield Program are provided at no cost to you.
BRT is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). In accordance with the Privacy Shield Principles, BRT remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless BRT proves that it is not responsible for the event giving rise to the damage.
In accordance with applicable data protection laws and the Privacy Shield Principles, you may have the right to submit requests relating to their personal data (i.e., access, rectification, and erasure of personal information; restriction of processing of personal information; objecting to certain processing of personal information; and the right to data portability). Where any processing of personal information is solely dependent upon your consent, you may also have the right to withdraw such consent at any time (For example, we suggest by using the any unsubscribe link contained in an applicable marketing message, or, emailing us at the “Communications” details below). Please note that if you revoke your consent for the processing of information then we may no longer be able to provide you certain BRT Services. We may limit or deny your request to revoke consent if the law and/or Privacy Shield Principles permits or requires us to do so, if we are unable to adequately verify your identity, or if our processing is not based on your consent. Where you believe that we have not processed your personal information in accordance with applicable data protection laws and the Privacy Shield Principles, you may lodge a complaint with the respective supervisory authority or data protection regulator. To exercise your rights under these provisions, please contact us at the “Communications” details above. When we receive your requests, we may ask you to verify your identity before we can act on your request.
Under the Privacy Shield Principles, individuals may have the right to opt out of (i) disclosures of their personal information to third parties; or (ii) uses of their personal information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individual.
While no service is completely secure, BRT takes reasonable measures designed to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For example, our policy is to encrypt your content when it is stored in our data centers. In addition, sensitive information such as credentials and passwords that we request from you on the BRT Services is designed to be protected with encryption, such as Secured Socket Layer (SSL) protocol, during transmission over the Internet.
While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable. No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. In addition, we cannot guarantee that any passively-collected personal information you choose to include in documents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.
You may access your account information and our service only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.
Other Sites and Services
The BRT Services may contain links to websites, mobile applications or other online services operated by third parties. When you click on a link to any other website, mobile application or online service, you will leave the BRT Services and go to another site, and another entity may collect personal information or anonymous data from you. In addition, our content may be included on other online services that are not associated with us. We have no control over, do not review, and are not responsible for, these third party online services or for their content or actions. Other online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of other online services that you visit or use. The links to third party online services are for your convenience and do not signify our endorsement of, or affiliation with, any third party or its services.
Update, Correct, or Delete Account Information
You may update, correct or delete information about you at any time by logging into your BRT Service account. If you wish to deactivate your account, please email us at [email protected], but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time. We will respond to your access request within 30 days. To request removal of your personal information from our blog or testimonials, contact us at the email address listed above. 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.
Opt-Out of Promotional and Newsletter Communications
You may opt out of receiving promotional and newsletter emails from BRT by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing [email protected] with your specific request. If you opt out, we may still send you non-promotional communications, such as security alerts and notices related to your access to or use of the BRT Services or those about your online account or our ongoing business relations.
Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the BRT Services and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
We use Google Analytics to help us understand user activity and patterns on the BRT Services. You can learn more about these cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of the BRT Services by downloading and installing a browser plugin available here.
You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt-out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites:
- Network Advertising Initiative – http://www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance – optout.aboutads.info
The opt-out preferences described above must be set on each device and/or browser for which you want them to apply. Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies. For example, we may work with Facebook and Google to help us with advertising the BRT Services and our business. You can learn more about and find opt-out instructions for Google by clicking here and Facebook by clicking here. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Your California Privacy Rights
Under California law, California Residents who have an established business relationship with BRT may choose to opt out of BRT’s disclosure of personal information about them to third parties for direct marketing purposes. If you wish to “opt out”, please contact BRT with such request via email at [email protected] or via mail at Blue Ribbon Technologies, 6030 Greenwood Plaza Blvd, Suite 110, Greenwood Village, Colorado 80111, Attn: Privacy Department.
Other Rights Under Applicable Law
You may have additional rights, in accordance with applicable laws, to access, update, correct, and in some cases requests deletion of the personal information that we hold about you. When updating your personal information, we may ask you to verify your identity before we can act on your request. Any access request will be subject to the relevant fee, if any, to meet our costs in providing you with details of the information we hold about you. We will comply with required requests as soon as reasonably practicable and in accordance with applicable laws. We may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations, or to complete any transactions that you began prior to requesting such change or access.
Communications; Contacting Us
If BRT needs, or is required, to contact you concerning any event that involves information about you, we may do so by email, telephone, or mail.