Last Updated: May 2018
Privacy is paramount to us. This privacy statement explains the personal data Shine Analytics Limited and its affiliates (“Brightflag”) process, how Brightflag processes it, and for what purposes. Brightflag offers a cloud-based software platform used by companies worldwide to understand and manage legal spend. References to Brightflag products in this statement include Brightflag services, websites, apps and software. Please refer to the product-specific details in this privacy statement for additional information on how the tools process data. This statement applies to Brightflag’s interactions with you and the Brightflag products listed below, as well as other Brightflag products that display this statement.
This Privacy Notice explains:
We've tried to keep it as simple as possible, but if you're not familiar with terms, such as cookies, IP addresses, pixel tags and browsers, then read about these key terms first. Your privacy matters to us, so whether you are new to us or a long-time user, please do take the time to get to know our practices – and if you have any questions, contact us.
Brightflag collects data from you, through our interactions with you and through our products. You provide some of this data directly, and we get some of it by collecting data about your interactions, use and experiences with our products. The data we collect depends on the context of your interactions with Brightflag and the choices you make, including your privacy settings and the products and features you use. We also obtain data about you from third party applications running on this website.
You have choices when it comes to the technology you use and the data you share. We collect information to provide better services to all of our users – from figuring out basic stuff like which language you speak, to more complex things like which information from our website was most relevant to you. We collect information in the following ways:
Information we collect when you are signed in to Brightflag or visit our website as a guest, we treat it as personal information.
When we ask you to provide personal data, you can decline. If you choose not to provide data necessary to provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use such data will not work for you.
Brightflag uses the data we collect to provide you rich, interactive experiences. In particular, we use data to:
We also use the data to operate our business, which includes analysing our performance, meeting our legal obligations, developing our workforce, and doing research.
In carrying out these purposes, we combine data we collect from different contexts (for example, from your use of two Brightflag products) or obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.
We share your personal data with your consent or to complete any transaction or provide any product you have requested or authorized.
We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we have hired to assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.
Finally, we will retain, access, transfer, disclose, and preserve personal data, including your content, when we have a good faith belief that doing so is necessary to:
Please note that some of our products include links to products of third parties whose privacy practices differ from Brightflag’s. If you provide personal data to any of those products, your data is governed by their privacy policies.
You can also make choices about Brightflag's collection and use of your data. You can control your personal data that Brightflag has obtained, and exercise your data protection rights, by contacting Brightflag or using various tools we provide. How you can access or control your personal data will depend on which products you use. For example, you can:
You can access and control your personal data that Brightflag has obtained with tools Brightflag provides to you, described below, or by contacting Brightflag. For instance:
You can also object to or restrict Brightflag’s use of your personal data. For example, you can object at any time to our use of your personal data:
You may have these rights under applicable laws, including the EU General Data Protection Regulation (GDPR), but we offer them regardless of your location.
If your organization, such as your employer, partner or service provider, provides you access to and is administering your use of Brightflag products, contact your organization to learn more about how to access and control your personal data.
If you cannot access and control certain personal data collected by Brightflag via the tools above or directly through the Brightflag products you use, you can always contact Brightflag at DPO@brightflag.com or by using our web form. We will respond to requests to control your personal data within 28 days.
Your Communications Preferences
You can choose whether you wish to receive promotional communications from Brightflag by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to opt out, you can do so by following the directions in that message. You can manage your Brightflag email contact preferences by using this web form. These choices do not apply to mandatory service communications that are part of certain Brightflag products, programs, activities, or to surveys or other informational communications that have their own unsubscribe method.
Your Advertising Choices
To opt out of receiving interest-based advertising from Brightflag, please reply to the e-mail requesting so. When you opt out, your preference is stored in a cookie that is specific to the web browser you are using. The opt-out cookie has an expiration date of five years. If you delete the cookies on your device, you need to opt out again.
Because the data used for interest-based advertising is also used for other necessary purposes (including providing our products, analytics, and fraud detection), opting out of interest-based advertising does not stop that data collection. You will continue to get ads, although they may be less relevant to you.
You can opt out of receiving interest-based advertising from third parties we partner with by visiting their websites.
When you use a browser, you can control your personal data using certain features. For example:
With a Brightflag account, you can sign into Brightflag products, as well as those of select Brightflag partners. Personal data associated with your Brightflag account includes credentials, name and contact data, payment data, device and usage data, your contacts, information about your activities, and your interests and favourites. Signing into your Brightflag account enables personalization and consistent experiences across products and devices, permits you to use cloud data storage, and enables other features.
Below you will find additional privacy information, such as how we secure your data, where we process your data, and how long we retain your data.
In the event of a conflict between this Brightflag privacy statement and the terms of any agreement(s) between a customer and Brightflag for any Brightflag product or services, the terms of those agreement(s) will control.
When a customer tries, purchases, uses, or subscribes to Enterprise Products, or obtains support for or professional services with such products, Brightflag collects data to provide the service, including uses compatible with providing the service, provide the best experiences with our products, operate our business, and communicate with the customer. For example:
Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority or Brightflag’s supervisory authority, the Irish Data Protection Commissioner (Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland, email@example.com). However, we would ask that you contact us first so that we can try to address your concerns.