Last updated: 6 October, 2019
1. WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?
The categories of information we collect can include:
Information you provide to us directly: We may collect personal information such as a username and password, first and last name, phone number, e-mail address, home address, and employer when you register for a Brightway account, use our Service, or if you correspond with us. We may also collect additional information you provide to us about your company or employer, your family, and your benefits, which we will consider to be personal information if it is linked to your identifying information. We may combine this information with data we collect from you through other methods, such as telephone conversations or electronic document exchange services, including your social security number, bank account number and other financial information.Information we collect from third parties: We may obtain Information about you from third parties, such as your employer, your payroll provider, and your elected benefit providers. We may collect information from consumer reporting agencies.
We use this information to operate, maintain, and provide to you the features of the Service. We may use this information to communicate with you, such as to send you email messages, and to follow up with you to offer information about our Service and your account. We may also send you Service-related emails or messages (e.g., account verification, transactional communications, change or updates to features of the Service, technical and security notices). For more information about your communication preferences, see “Your Choices Regarding Your Information” below.
We and our third party partners may automatically collect certain types of usage information when you visit our website or use our Service. For instance, when you visit our websites, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click, how frequently you access the Service, and other actions you take on the Service), and allow us to track your usage of the Service over time. We may collect log file information about your browser or mobile device each time you access the Service. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Service. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time, as we believe that there is no consistent industry standard for how to respond to Do Not Track browser settings.
When you access our Service by or through a mobile device, we may receive or collect and store a unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.
We may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including advertising; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Service; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our service.
Third Party Tracking and Online Advertising:
We may permit third party ad networks, social media companies, and other third party services to collect information about browsing behaviour from visitors to our Service through cookies, social plug-ins, or other tracking technology. We may permit third party online advertising networks to collect information about your use of our websites over time so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites or services. Typically, the information is collected through cookies or similar tracking technologies. The only way to completely “opt out” of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device. Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. (To learn more about cookies, clear gifs/web beacons and related technologies and how you may opt-out of some of this tracking, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org). Depending on your mobile device, you may not be able to control tracking technologies through settings.
3. SHARING OF YOUR INFORMATION
We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Your Choices About Your Information” section below.
We may share your personal information with:
Other parties you chose to share data with through our Service. This includes your employer, your benefits providers, and any other company or individual you engage with through our Services;
Other companies owned by or under common ownership as Brightway Holdings Sdn Bhd. These companies will use your personal information in the same way as we can under this policy;
Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, billing, payments, background check services, service fulfilment, web hosting or providing analytic services;
Our business partners who offer a service to you jointly with us, or who partner with us to provide our Services to you;
Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of a bankruptcy or related or similar proceedings; and
Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Brightway Holdings Sdn Bhd, our Users, or others.
We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.
4. YOUR CHOICES ABOUT YOUR INFORMATION
How to control your communications preferences:
You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, benefits registration, transactional communications, changes/updates to features of the Service, technical and security notices).
Modifying or deleting your information:
We will retain your information for as long as your account is active or as needed to provide you Services. You may view and modify your personal information through your account settings. We may not be able to modify or delete your information in all circumstances, as federal and state law may require that we maintain certain types of information for a set period of time. You may not be able to delete or modify certain information that your employer requires that we maintain. If you have any questions about reviewing, modifying or deleting your account information, you can contact us directly at email@example.com
5. HOW WE STORE AND PROTECT YOUR INFORMATION
Storage and Processing:
Keeping your information safe:
Brightway Holdings Sdn Bhd cares about the security of your information, and uses robust and state-of-the-art physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through the Service. However, no security system is perfectly secure and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, Brightway Holdings Sdn Bhd will investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
6. LINKS TO OTHER WEB SITES AND SERVICES
Our Service may integrate with or contain links to other third party sites and services. We are not responsible for the practices employed by third party websites or services embedded in, linked to, linked from, or connected with the Service and your interactions with any third-party website or service are subject to that third party’s own rules and policies.
7. HOW TO CONTACT US