Privacy Policy

This Privacy Policy explains how BRIZZO (“BRIZZO”, “we”, “our”) collects, uses, maintains, and discloses information from users (“Users”) of our services and websites. This policy applies to all information we collect through our services, websites, and any other means. It is part of our contracts and is incorporated into our Terms of Service (TOS), Acceptable Use Policy (AUP), and any other contract we have with Users.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to BRIZZO.
• Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the advertisement, website, or application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Information We Collect

Information Contained in Your Customer Record

Users who are our customers provide us with their name, address, phone number, username, credit/debit card or bank information, and other personally identifiable or confidential information necessary to provide our services. We may also acquire information about customers from third parties, such as credit reporting agencies, and collect information about our customers’ use of the services. This information is referred to as “Registration and Billing Information”.

User Inquiries

Users who contact us with questions may be required to provide additional information to assist us in resolving their questions or in our business operations (referred to as “User Inquiry Information”).

Statistical Information

We collect information about Users’ use of our services and products in general, which may include referring URLs, connecting IP addresses, and CPU usage. This is referred to as “Statistical Information”.

Cookies and Tracking Software

We use cookies and tracking software for service provision and marketing purposes. Cookies are small data files placed on a User’s computer that are read by us to determine whether you have visited our site before, how often, the length of time, and which pages you view. Tracking software may observe Users’ use of our services or movement on specific web pages.

How We Use Collected Information

Subpoenas and Other Legal Demands

BRIZZO may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We will produce all information in our possession as required by law. We may also disclose this information to protect our business interests, including during the sale or acquisition of all or part of our business. If possible, we will notify Users before producing this information, unless prohibited by law or impractical.

Registration and Billing Information

We use Registration and Billing Information to identify Users personally. It is used to provide services, market new products and services, and ensure payment for services rendered. This information may be shared with third parties affiliated with us if they provide services to Users through us and those services are billed independently. Aggregate information based on Registration and Billing Information may be disclosed to third parties for marketing purposes.

Customer Inquiries

We use Customer Inquiry Information to identify Users personally and provide services. This information may be shared with third parties to identify and fix problems with our services. Providers of third-party products may require Customer Inquiry Information to provide their services. When shared, third parties are required to keep this information confidential.

Statistical Information

We use Statistical Information to operate our hardware and software, diagnose problems, and administer our website. This information is used in aggregate to modify our products and services based on visitor behavior and preferences.

Cookies

We use information provided by cookies to change the website’s appearance for Users, keep Users logged in to certain areas, ensure continued connection to our equipment, and collect demographic data about website usage.

Data Security

We use industry-standard security measures to protect the information set out in this Privacy Policy. No means of communication or information transmission or storage is entirely secure. We are not responsible for loss, corruption, or unauthorized acquisition and use of information, or for any resulting damages, including unauthorized acquisition and use. Unless otherwise stated, our employees are required to keep the information confidential.

User Rights and Options

Users have the right to access their personal data and limit its use and disclosure:

• Modify your Registration and Billing Information through your control panel.
• Request deletion of Customer Inquiry Information by contacting us through our contact form.

Special Privacy Rights

California Consumer Privacy Act (CCPA)

If you are a resident of California, you have the following rights:

• Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You have the right to request the deletion of your personal information, subject to certain exceptions.
• Right to Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights.

To exercise your CCPA rights, please refer to the “How to Contact Us” section below.

Brazil’s General Data Protection Law (LGPD)

If you are a resident of Brazil, you have the following rights:

• Right to Confirmation of the Existence of Processing: You can confirm whether your personal data is being processed.
• Right to Access: You can access your personal data.
• Right to Correction: You can request the correction of incomplete, inaccurate, or outdated data.
• Right to Anonymization, Blocking, or Deletion: You can request the anonymization, blocking, or deletion of unnecessary or excessive data.
• Right to Data Portability: You can request data portability to another service provider.
• Right to Information: You can obtain information about public and private entities with which we have shared your data.
• Right to Consent Revocation: You can revoke your consent to data processing.

To exercise your LGPD rights, please refer to the “How to Contact Us” section below.

Other State-Specific Privacy Rights (Colorado, Connecticut, Utah, Virginia)

Residents of Colorado, Connecticut, Utah, and Virginia have similar rights to those in California, including:

• Right to Access: You can request access to your personal data.
• Right to Correction: You can request the correction of inaccurate data.
• Right to Deletion: You can request the deletion of your personal data.
• Right to Opt-Out: You can opt-out of the sale of your personal data and targeted advertising.

To exercise your state-specific privacy rights, please refer to the “How to Contact Us” section below.

Privacy Complaints by European Union and Swiss Citizens

BRIZZO is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). BRIZZO complies with the EU-US Privacy Shield Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union and Swiss citizens. BRIZZO has certified that it adheres to the Privacy Shield and Safe Harbor Principles.

Contact Information for Privacy Complaints

BRIZZO has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Under certain conditions, you may have the right to invoke binding arbitration before the Privacy Shield Panel to be created by the US Department of Commerce and the European Commission.

Policy Updates

We may update this Privacy Policy from time to time. When we do, we will post the revised policy on our website and update the date at the top. If the changes are significant, we will provide a more prominent notice and/or seek your consent where required by law.

Information from Children

We do not knowingly collect, use, or disclose information from children under 16. If we learn that we have collected the personal information of a child under 16—or the equivalent minimum age depending on the jurisdiction, such as 13 in the United States per the Children’s Online Privacy Protection Act—we will take steps to delete the information as soon as possible. If you are under 16, do not provide any information about yourself to BRIZZO, including your name, address, telephone number or email address. If you become aware that information of a child under 16 years of age has been provided, please use one of the methods provided under the “How to Contact Us” section below.

Links to Other Websites and Services

We are not responsible for the practices employed by websites or services linked to or from the Platform, including the information or content contained therein. This Privacy Policy does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not operating on BRIZZO’s behalf, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure. This includes: (a) any third party operating any site or service to which the Platform links – the inclusion of a link on the Platform does not imply endorsement of the linked site or service by us or by our affiliates; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer (such as Facebook, Apple, Google, Microsoft, LinkedIn, etc.) – including any Personal Information you disclose to other organizations through or in connection with the Platform or other BRIZZO Services.

Do Not Track

Some browsers incorporate a “Do Not Track” (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.

Your Legal Rights

BRIZZO respects your rights in how your Personal Information is used and shared. Depending on where you live, you may have rights to request access or corrections to your personal data and make choices about the kinds of marketing materials you receive (or choose not to receive marketing from BRIZZO at all).

European Privacy Rights

If you are in Europe, you may have additional rights under the GDPR, the UK GDPR, or nFADP. Additional choices and rights may be available to you depending on which BRIZZO Services you use.

Access, Correction to or Deletion of Your Information

If you would like to correct or update your Personal Information, or to request access to or deletion of your Personal Information, you may contact us by visiting the Platform or by using the contact details provided under the “How to Contact Us” section below. If you request a change to or deletion of your Personal Information, please note that we may still need to retain certain information for recordkeeping purposes, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). Some of your information may also remain within our systems and other records where necessary for compliance with applicable law.

At your request and where the law requires us to do so, we will confirm what Personal Information we hold about you. You may also have a legal right to obtain a copy of your Personal Information. You can make such a request by making a written request in one of the ways described in the “How to Contact Us” section below. We may charge a processing fee for this service where permitted by law and we will require evidence of your identity before fulfilling your request.

Data Privacy Rights Specific to Individuals in the European Economic Area, the United Kingdom, and Switzerland

You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information, or request portability of your Personal Information. You can exercise these rights by making a written request in one of the ways described in the “How to Contact Us” section below.

Similarly, if we have collected your Personal Information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect (1) the lawfulness of any processing we conducted prior to your withdrawal, or (2) processing your Personal Information under other legal bases.

If you believe we are using your Personal Information in a way that is inconsistent with this Privacy Policy or for more information about your rights, contact your local data protection authority. Additionally, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF, you may contact JAMS Mediation, Arbitration, and ADR Services (https://www.jamsadr.com/eu-us-data-privacy-framework) to address complaints and provide appropriate recourse free of charge to you. Under certain conditions, you may invoke binding arbitration.

Advertising and Marketing Choices

We give you many choices regarding our use and disclosure of your Personal Information for advertising and marketing purposes. You may access or update your contact details and modify your communication preferences by using one of the methods provided under the “How to Contact Us” section below. Please also note that if you choose not to receive marketing communications from us, we may still send you communications related to your products or the Platform, such as information about a security update, service issue or product delivery. Some advertising content is delivered through the Platform’s use of cookies and similar technologies. Our Cookies Policy includes more information on BRIZZO’s use of such technologies for advertising and other purposes.

International Compliance

BRIZZO is a global company with its headquarters in the United States. As such, we may transfer your Personal Information between the United States and our affiliates and business partners in other countries. We may also transfer your Personal Information to our third party service providers, who may be located in a different country to you.

BRIZZO transfers information internationally in order to operate efficiently, to improve performance, and to create redundancies to protect information in the event of an outage or other problem. In so doing, we will process your Personal Information in a way that meets the commitments of this Privacy Policy and complies with the law wherever we transfer it.

Whenever BRIZZO transfers Personal Information beyond the country of origin, we will do so in accordance with applicable laws. For Personal Information originating in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland that is transferred to a BRIZZO entity outside the EEA, UK, or Switzerland, BRIZZO participates in the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and, as applicable, the UK extension to the EU-U.S. DPF, and/or the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). BRIZZO commits to the DPF Principles and, as needed, will take additional steps to provide appropriate safeguards for the Personal Information we transfer. The Federal Trade Commission has jurisdiction over BRIZZO’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. BRIZZO may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. BRIZZO is liable in cases of onward transfers to third parties.

Data Privacy Framework

BRIZZO complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. BRIZZO has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. BRIZZO has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

How to Contact Us

To ask questions about this Privacy Policy and our privacy practices, contact us by mail, e-mail or use our contact form: