·The types of information we may collect or that you may provide when you download, install, register with, access or use the Bright mobile application (the “App”), or interact with our website choosebright.com (the “Site”) (together, the “Services”); and
Our practices for collecting, using, maintaining, protecting and disclosing that information.
Last Updated March 19, 2021
Collection of your Information
What Information do we collect?
When you use our Services, we collect and use several types of Information from and about you, including:
Personal Information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, IP address, credit card and billing information. When you register with us, through the Site or App, we collect the following Personal Information:
Full date of birth;
Descriptive information about your general state of well-being (you are asked to rate, on a scale of 1-10, how true certain statements are for you, such as “I feel good about myself”, or “I eat a healthy, balanced diet”, or “I am comfortable with my current financial situation”).
Non-identifiable Information, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Site or App feature.
Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Site, and usage details.
Information about your Site and App interactions, including the full URLs, clickstream to, through and from our Site and/or App (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.
How do we collect Information?
We only collect Information that we believe is reasonably necessary to provide the Services to you, and as otherwise described in this Policy. We use different methods to collect your Information, including through:
Direct interactions with you when you provide it to us, such as when you book Services offered through the Site or App, ask to receive emails and/or text messages, or when you correspond with us through the Site or App, by email, phone, or otherwise.
Third parties or publicly available sources, such as other users of the Site or App, our business partners and service providers, and unaffiliated third parties (such as advertising networks).
We may collect Information that you, or another, provides directly to us by filling in forms, and Non-identifiable Information that we collect from cookies or tracking software we utilize. In addition to Information collected through your use of our Services, we may also collect Information in other ways such as over the phone, via email and through location tracking devices as further described below.
The choice to provide us with Personal Information is yours, and you can withdraw your consent with respect to our collection and use of your Personal Information at any time. In certain cases, your decision to withhold Information may limit the Services that we can provide to you through the Site or App.
Some of the cookies used by us are essential for the functioning and performance of our Site and App, such as by making our Site and App work more efficiently and facilitating your use of the functionalities and services provided; these functionality and/or performance cookies will be deleted from your device once your browser-session has ended (session cookies). We will not use the information stored in essential cookies for any other purpose than as strictly necessary to provide you with the services and functionalities requested.
You can opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
Use of your Information
i. to provide you with access to the Services;
ii. to provide you with information relating to our Services;
iii. to provide you with information, Services that you request from us;
iv. to follow up on your comments and suggestions;
v. to fulfil the purposes for which you provided the Information or that were described when it was collected, or any other purpose for which you provide it;
vi. to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;
vii. to notify you about changes to our Services we offer or provide through our Site or App;
viii. to improve our Site or App, Services, marketing, or customer relationships and experiences;
ix. to manage and develop our business systems and operations;
x. to monitor and conduct an analysis of our Site and App traffic and usage patterns;
xi. to post customer testimonials, comments or reviews;
xii. to protect our rights and property; or
xiii. to lessen a serious threat to personal safety, health or security.
Recordings, which may include Personal Information such as your image or voice, may also be distributed published, displayed, performed, transmitted, streamed, broadcasted, or made available to Providers, other customers, third parties, or the public in order to provide such persons with access to the content of the Recordings in connection with our business.
Disclosure of your Information
We reserve the right to share any Information collected from you with entities that are affiliated, controlled by or under common control with Bright, or to transfer such Information to a successor entity or to an entity which purchases substantially all of the assets of Bright.
We sometimes contract with outside organizations to perform specialized services such as hosting the Site and App. Our suppliers may at times receive, process or handle some of your Information. Only the Information necessary to perform the services under the contract is given to the supplier. Under their contracts with us, our suppliers may use such Information only to carry out the contracted service and must not store or use the Information for any other purpose. Our contracts with suppliers require that they provide a level of protection for your Information that is comparable to our own, and that complies with applicable laws.
We may also disclose your Information:
To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
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 Bright, our customers, or others. This includes exchanging information with our service providers and affiliates for the purposes of fraud protection and credit risk reduction.
We may process, store, and transfer your Personal Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
The security of your Personal Information is important to us. To ensure that your Personal Information is secure, we have put in place commercially suitable procedures to safeguard the Information we collect against unauthorized use, disclosure, or modification. Nonetheless, transmission of information on the internet is not completely secure. Therefore, we cannot guarantee the security of data sent to us electronically on our Site, through our App, by email or otherwise and transmission of such data is therefore entirely at your own risk. Likewise, the storage of information is not completely secure and we cannot guarantee the security of data stored on our system and storage of such data is therefore entirely at your own risk. Notwithstanding anything in this paragraph, we will comply with all applicable laws related to the security standards we must apply to our services, including data collection, transmission and storage, to be and remain compliant with those laws when we collect, use, handle or store your Personal Information.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize or aggregate your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
Our Services are not intended for persons under the age of majority, and we do not knowingly collect Personal Information from minors. If you believe we might have any information from or about a minor, please contact us at the address provided below.
Updating your Information and Correcting Errors
It is important that your Personal Information be accurate and up-to-date. If any of your Personal Information changes, is inaccurate, or is incomplete, please inform us by contacting us at the address provided below so that we can make any necessary changes. You can also log into your account and update your Personal Information at any time. By law, you may have the right to require us to give you access to, verify, erase or amend all of your Personal Information that we hold about you.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Withdrawing your Consent
Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at the address provided below. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.