The Privacy of our Users (“User” or “you”) is important to SR Data Systems Co. Inc. d/b/a BR data (“BR Data” “us” or “we”). This Privacy Policy (“Privacy Policy”) describes how we collect, use, and share (collectively referred to as “process” or “processing activities”) your Personal Information (“Personal Information” or “Personal Data”) and explains your rights in connection with your use of our websites and applications (the “Site”) and other Services provided by us and referring to this Privacy Policy (collectively referred to herein as the “Services”).
Please take a moment to familiarize yourself with our privacy practices, and contact us at the information below if you have any questions or comments about this Privacy Policy, the ways in which BR Data processes your Personal Information, your choices and rights regarding such processing, or wish to exercise your rights under this Privacy Policy.

BR Data reserves the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Site and update the effective date displayed at the top of this webpage. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

You can contact us at:
BR Data
175 Pinelawn Road, Suite #305 Melville,
NY 11747
Phone: (631) 391-8840
Email: support@brdata.com

I. SCOPE AND EXCLUSION

This Privacy Policy is adopted in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) and applies to the processing of Personal Information collected by us by BR Data as Data Controller (as defined by the CCPA) for the processing of the Personal Information of our Users.

This Privacy Policy covers how BR Data handles your Personal Information whether you interact with us on our websites, through apps, or in person (including by phone). This Privacy Policy applies to information that can be used to identify you and that you provide to BR Data or which is derived from the Personal Data as outlined below. Additional terms may apply if you decide to purchase certain Services, these terms will be presented to you in advanced.

This Privacy Policy does not apply to the extent we process Personal Information in the role of a processor or service provider on behalf of our registered users (“Customer”), including where we offer to our Customers various products and services through which our Users (or their Affiliates): (i) create their own platform running on our BR Data Cloud Services; (ii) sell or offer their own products and services; (iii) send electronic communications to others; or (iv) otherwise collect, use, share or process Personal Data via the BR Data Cloud Services. For detailed privacy information related to BR Data Customers or a Customers Affiliates who uses the BR Data Cloud Services as the controller, please contact our Customers directly. We are not responsible for the privacy or data security practices of our Customers, which may differ from those explained in this Privacy Policy.

This Privacy Policy does not apply to products or services offered by other companies or individuals, such as payment processing services, hardware or third-party software, that Users may use in connection with the Services, including such third-party products or services that a User may lease or procure through BR Data.

Children. We do not knowingly collect personal Information from individuals under the age of 18. Our Site is not directed at individuals under the age of 18. If you have reason to believe that an individual under the age of 18 has provided Personal Information to us, we encourage the individual’s parent or guardian to contact us as described in the “Contact Us” section of this Privacy Notice to request that we remove the information from our systems.

2. THE DATA WE COLLECT

BR Data only collects Personal Information in compliance with this Privacy Policy. BR Data collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

2.1 Personal Data we collect directly from you

The Personal Data we collect directly from you in the normal course of business includes contact information (such as name, address, phone number, email address, and your employer) and payment details.

We collect such information in the following situations:

• If you express an interest in obtaining additional information about our Services; request support or similar features; register and/or set up a user account on the Site.
• If you interact with our Site or emails us, we may collect information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Information using cookies, web beacons, or similar technologies;
• If you use and interact with our Site, we automatically collect information about your device and your usage of our Site through log files and other technologies, some of which may qualify as Personal Information;

If you provide us with any Personal Data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Policy. If you believe that your Personal Information have been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us at support@brdata.com.

You are not required to provide the Personal Information that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with certain products or services or respond to requests you may have.

2.2 Personal Information we collect indirectly

BR Data may receive Personal Information about you from other individuals, businesses or third parties acting at your direction, from our partners who work with us to provide our products and services and assist us in security and fraud prevention, and from other lawful sources. We may combine this information with Personal Information provided by you to helps us update, expand, and analyze our records, identify new Users, and create more tailored products to provide services that may be of interest to you. The Personal Information we collect from other sources may include identifiers, professional or employment-related information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors.

In particular, we collect such Personal Information from the following sources:

• Third party providers of business contact information, including mailing addresses, email addresses, phone numbers, User behavior data, IP addresses, social media profiles for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying contact information; and
• Personnel or employees at your organization who may provide us with your business contact information for the purposes of using the Site; and
• We may also collect Personal Information from publicly accessible sources

2.3 Aggregated and anonymized Information

Personal Information about you may in some cases directly identify you, while in other cases it may only indirectly identify you. For research and development purposes, we may use datasets such as those that contain images, or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law, including law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to reidentify individuals who may appear therein.

3. BUSINESS PURPOSES FOR COLLECTING YOUR PERSONAL INFORMATION

Where required by law, we obtain your consent to use and process your Personal Data for these purposes. Otherwise, we rely on another authorized legal basis (including but not limited to the (a) performance of the business purposes of a contract or (b) legitimate interest to collect and process your Personal Data.

We process your Personal Data for the following business purposes:

• Manage our customer relationship;
• evaluate and improve the Site;
• meet our commitments to you;
• respond to the request or inquiry submitted to us through the contact form or other entry field, to
  initiate business or perform a contract;
• auditing related to a current interaction with you, and concurrent transactions including but not limited to, counting ad impressions to Users, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• debugging to identify and repair errors that impair existing intended functionality;
• short-term, transient use, provided the PI that is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction including but not limited to, the contextual customization of ads shown as part of the same interaction;
• performing services on behalf of a business or service provider with whom we have a relationship including but not limited to, maintaining or servicing accounts, providing User service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider;
• undertaking internal research for technological development and demonstration;
• manage and develop our business and operations;
• send reminders, technical notices, updates, security alerts and support, administrative messages, service bulletins and marketing information;
• add to our contact database;
• manage our everyday business needs, such as Site administration, forum management, fulfillment, analytics, enforcement of our corporate reporting obligations, applicable terms, or to comply with the law; and
• send marketing communications: We will process your PI or device and usage data, which in some cases may be associated with your PI, to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, or push notifications) about BR Data including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see the “Your Privacy rights” Section 9, below, to learn how you can control the processing of your Personal Data by BR Data for marketing purposes).

4. SHARING OF YOUR PERSONAL INFORMATION

We may share your Personal Information as follows:

• With Third party services providers whom we may rely on to run or help us to run surveys and promotional activities. In some situations, they provide services relating, but not limited to fraud detection and prevention, credit card processing, billing, system administration, User support, internet and connectivity, marketing (through direct mail, email, lead generation, etc.), event organizing, security, and user experience for the purposes and pursuant to the legal purposes described above; BR Data has Data Processing Agreement with such service providers limiting their use of and access to Personal Information;
• With Affiliates (such as our subsidiaries and other companies owned and/or controlled by or affiliated with, BR Data) who may only use the Personal Information for the legal purposes described in Section 3 above;
• With Customers with whom you are affiliated: If you use our Services as an authorized user on behalf of a Customer, we may share your Personal Information with such affiliated Customer responsible for your access to the Site to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies;
• With your consent; we may share your PI when we have your express consent. For example, when you choose to procure a third-party service through the BR Data Cloud, or use a third-party application that requests access to your information, we will only share information with your prior and express consent.
• Professional Advisers: In individual instances, we may share your PI with professional advisers acting as service providers, processors, or joint controllers – including attorneys, bankers, auditors, and insurers and to the sole extent we are legally obliged to share or have a legitimate interest in sharing your PI; and
• In the Context of a Corporate Transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Information to an unaffiliated third party.
• To defend ourselves in litigation or a regulatory action and when required or advised to do so by
  law or our legal counsel in their representation of us. This includes but is not limited to, in response to a subpoena or similar legal proceedings, including to law enforcement agencies, regulators, and courts in the United States and other countries.
• We may also share anonymous or de-identified usage data with BR Data’s service providers for the purpose of supporting such analysis and improvements. Additionally, BR Data may share such anonymous or de-identified usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our Site.
• Anyone using our online communities, forums, blogs, or chat rooms on our websites may read any Personal Information or other information you choose to submit and post.

5. WEBSITES AND DATA COLLECTION OF THIRD PARTIES

The Site may include links to other websites or service, such as to purchase online subscriptions, purchase
physical goods, interactive games, or purchase of a virtual goods or services. Personal information collected on other sites and services is subject to the privacy policy and practices of the third party providing such website or service and not this Privacy Policy. Similarly, on the Site or portions of the Site that are not directed to children, we may give you the option to share with others on social media platforms, such as Instagram, Facebook or Twitter. When you share in this manner, the privacy practices of the social media platform control who has access to your information and how it is treated by the social media platform.

Please consult the privacy policies of any social media services or other third parties with which you share information in this manner to learn about the social media platform’s data practices.

6. PERSONAL INFORMATION RETENTION

BR Data retains Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Services to you; (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).

7. HOW IS INFORMATION ABOUT YOU SECURED?

We store the Personal Information we collect for as long as it is necessary for the purpose(s) for which we originally collected it. We may also retain personal information as required by law. Wherever your personal information is stored by us, we will take reasonable steps to safeguard the privacy of your personal information. These steps may include implementing standard contractual clauses were recognized by law, obtaining your consent, or other lawful means of transferring personal information.

BR Data cares about the security of your information, and uses commercially reasonable physical, administrative, and technological safeguards to help preserve the integrity and security of all personal Information collected. BR Data undertakes to implement and maintain, at its own expense, appropriate technical and organizational measures regarding the processing and security of personal information, in accordance with the applicable personal information protection laws. We ensure that these technical and organizational measures are, at all times, adapted to the particular risks presented by its processing activities, with regard to the nature of the information collected, in particular, to protect the personal information against accidental or illicit destruction, loss, modification, unauthorized disclosure or access.
Thus, regarding the technical measures put in place by BR Data:

• all Personal Information is stored and backed up on remote servers protected against third
  party attacks;
• our databases are secured by complex passwords;
• computer stations are locked automatically and can only be unlocked with a login and
  password;
• management software is only accessible with usernames and passwords. As far as organizational measures are concerned, only certain managerial employees of BR Data or authorized Service Providers performing contractual obligations requiring the transfer of certain Personal Information, are authorized to access the Personal Information. We also undertake to keep, update and preserve complete and accurate records concerning the
  processing of personal information that it implements. These records detail its processing activities.

In the event that any 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 Users whose personal information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

8. WHAT COOKIES, PIXEL TAGS AND OTHER SIMILAR TECHNOLOGIES DO WE USE?

Cookies and similar technologies (e.g., pixels tags and device identifiers) are routinely used on internet
platforms.

Cookies are small text files that contain a string of characters and uniquely identify a browser on a connected device. We may use cookies to, among other things, track user trends and collect information about how you use our Users’ sites or interact with advertising. Most browsers are initially configured to accept cookies by default. You may, however, be able to change your browser settings to cause your browser to refuse third-party cookies or to indicate when a third-party cookie is being sent. Pixel Tags (also called web beacons or clear GIFs) are invisible 1 x 1 pixels that are placed on webpages that use this technology for marketing and measurement purposes. When you access these webpages, pixel tags generate a generic notice of the visit. Pixel tags can be used with cookies or alone. When used with cookies, pixel tags can track activity on a site by a particular device and provide relevant online advertising to you. When you turn off cookies or have opted out of cookies, pixel tags simply detect a unique website visit and how you interacted with the advertising but do not track an individual to provide relevant online advertising.

We (including our service providers working on our behalf) utilize cookies to collect information about your activity, or activity on devices associated with you, on our Site. Cookies can help us to provide you with a more relevant experience when you browse the Site. For example, to recognize you and/or your device(s) for the purposes specified in Section 3 above (e.g., to provide secure log-in; remember how far you are through an order; remember your log-in details; make sure the website looks consistent, etc.). Please refer to Section 9 below for more information about your opting out tools.

Additionally, we utilize cookies to compile anonymous, aggregated statistics that allow us to understand how you and other users interact with the Site, and to improve the functionality and performance of the Site. Some cookies are set by us (first party cookies); some cookies are set by another party’s website (third party cookies). However, we do not allow the third party to use the cookies for any purpose other than those listed above.

Manage cookies. Some people prefer not to allow cookies, which is why most browsers give you the ability to manage cookies to suit you. In some browsers you can set up rules to manage cookies on a siteby-site basis, giving you more fine-grained control over your privacy. What this means is that you can disallow cookies from all sites except those that you trust.
Web browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information.

• Google Chrome
• Internet Explorer
• Microsoft Edge
• Mozilla Firefox
• Safari (Desktop)

For other browsers, please consult the documentation that your browser manufacturer provides. You can opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://youradchoices.com). In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads.
If you limit the ability of websites and applications to set cookies, you may worsen your overall user experience and/or lose the ability to access the services, since it will no longer be personalized to you. It may also stop you from saving customized settings, like login information.

9. YOUR PRIVACY RIGHTS?

Pursuant to the California Consumer Privacy Act (CCPA), and other applicable laws and regulations, individuals in certain jurisdictions may have data subject rights enabling them to opt-out of third party sharing or selling, delete or remove, or request to access and receive a copy of their Personal Information in BR Data’s possession or for which BR Data is otherwise responsible.

Opt-out. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by contacting us in accordance with the “Contact Us” Section below or by using the opt-out mechanism contained in each such email. We will try to comply with your request(s) as soon as reasonably practicable. If you opt out, we may still send you non-promotional communications, such as emails about your account or orders from us. We do not send marketing communications to children.

Do Not Track. Do not track signals and requests are sent from your browser to websites you visit indicating you do not want to be tracked or monitored. Websites are not required to accept these requests and many do not. At this time, our Site does not honor do not track signals or requests.

Depending on the applicable law in your jurisdiction, you may have additional rights, such as rights to access, correction and deletion of your Personal Information. If you have any questions about what rights and choices apply in your jurisdiction, please feel free to contact us at support@brdata.com.

10. YOUR CALIFORNIA RIGHTS

If you are a California resident, this Section 10 applies to you.

1. CCPA Categories
BR Data does not “sell” (as defined by the CCPA) your Personal Information.

We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Personal information does not include information that is publicly available, information that has been deidentified or aggregated, or information exempt from the purview of the CCPA, such as:

• Protected Health Information (“PHI”) governed and protected by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data; and
• Personal Information regulated by certain industry-specific privacy laws, such as the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, when you register on our Site or purchase our Services.
• Indirectly. For example, from observing your use of our Services

Please refer to Sections 1 through Section 4 and Section 8 above, for more information regarding the Personal Information we collect, the business purposes and how we process the information, and who we share your Personal Information with.

2.California Resident Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information. This Section describes your CCPA rights and explains how to exercise those rights regarding PI we have collected directly from you. For information that our Customers or another company has collected from their customers or other individuals, you must contact that company for assistance. For instance, an individual that does business with one of our Customer must contact that company in order to exercise their rights regarding Personal Information that company has collected about the individual in question.

Right to Access specific data and Portability. California residents have the right to request that we disclose certain information about our collection and use of Personal Information over the last twelve (12) months. Once we receive and confirm your verifiable consumer request, in which we may have to gather further identifiable information in order to confirm your identity, we will disclose to you the following:

• The categories of Personal Information we collected about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting or selling that Personal Information;
• The categories of third parties with whom we share that Personal Information;
• The specific Personal Information we collected about you (also called a data portability request); and
• If we disclose your Personal Information for a business purpose, identifying the Personal Information categories disclosed.

Right to Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

• Complete the transaction for which we collected the PI, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Right to Opt-Out of the Sale of Your Information. BR Data does not sell your Personal Information, as it is defined in the CCPA, will not sell Personal Information in the future, and in the preceding twelve (12) months, has not sold any Personal Information.

Request Submissions. To exercise the access, data portability, and deletion rights described above, please submit a Verifiable Consumer Request to us by either:

• Calling us at (631) 391-8840.
• Emailing us at support@brdata.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

A verifiable request may be submitted by a California resident or a person registered with the California Secretary of State that is authorized to act on your behalf. These requests for access and deletion may only be made twice during a twelve (12) month period and must:

• Detail sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Timeframe for Responding to Requests and Format: BR Data will respond to your request within thirty (30) days of receipt.

The period of response may be extended to forty-five (45) or up to (90) days if more time is required. In that event, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

No Discrimination, The CCPA prohibits a business from discriminating against California consumers for exercising the rights outlined above. We will not discriminate against you for submitting such requests by:

• Denying goods or services to you;
• Charging different prices or rates for goods or services, including through the use of discounts, benefits, or other penalties;
• Providing a different level or quality of goods or services; and
• Suggesting a different price or quality of goods or services will apply if rights are exercised.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

11. LINKS TO OTHER WEBSITES AND THIRD PARTIES

We provide links to other websites for informational purposes, for your convenience, or to offer additional services through separate websites and, depending on your device and settings, applications (commonly referred to as “apps”) linked to our Site (“Linked Websites”). Linked Websites are independent from our Site and are not governed by this Privacy Policy. We do not review, have control over their content or endorse Linked Websites or the information, software, products or services available on the Linked Websites. We also have no control over the privacy practices used by Linked Websites. If you decide to access any of the Linked Websites, you do so at your own risk.

12. CONTACT US

If you have any questions or comments about this notice, the ways in which BR Data collects and uses your information or wish to exercise your privacy rights, please do not hesitate to contact us at:

BR data
175 Pinelawn Road, Suite #305 Melville,
NY 11747
Phone: (631) 391-8840
Email: support@brdata.com