BRIM

Effective date: July 26, 2019

We at Looky Labs, Inc. (“Looky Labs” or “Company”) know you care about how your Personal Data is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. This Privacy Policy is a binding contract between you and Looky Labs. By using or accessing our website(s), products, services and applications (“Services”) in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

If you are a resident of the European Union (“EU”), Switzerland, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined herein. If you have any questions about this Privacy Policy or whether any of the following applies to you, please contact us at info@brimsecurity.com. Remember that your use of Looky Labs’ Services is at all times subject to the agreement you have entered into (or will enter into) with Looky Labs. In the event of a conflict between the terms or conditions of such agreement and this Privacy Policy, the terms of such agreement shall control.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of personally identifiable information, including “Personal Data” as it is defined in the GDPR (“Personal Data”) that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. For this Privacy Policy, we also use the term “processing” as it is defined in the GDPR, which generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. In certain circumstances, we may be the controller of your Personal Data processed in connection with the Services. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

We gather various types of Personal Data from our users, as explained in more detail below, and we use this Personal Data internally in connection with our Services, including to personalize, provide, and improve our Services, to allow you to set up a user account and profile (if applicable), to contact you and allow other users with whom you have voluntarily interacted on discussion boards or chat areas on the Services to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Data with third parties, but only as described below.

We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at info@brimsecurity.com.

Will Looky Labs ever change this Privacy Policy?

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the Services, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What Information does Looky Labs Collect?

Information You Provide to Us

We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Data including, without limitation, the following:

Certain information may be required to register with us or to take advantage of some of our features.

We may communicate with you if you’ve provided us the means to do so. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by contacting us at info@brimsecurity.com or by following the opt-out instructions contained in any emails from us.

Information Collected Automatically

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include the following:

“Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. If you click on a link to a third party website or service, such third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services - for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.

Information Collected From Other Websites and Do Not Track Policy

Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.

Information Collected from Third Parties

How do we use Personal Data?

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Will Company Share Any of the Personal Data it Receives?

We do not rent or sell your Personal Data in personally identifiable form to anyone, except as expressly provided below. We may share your Personal Data with third parties as described in this below:

Information that’s been de-identified: We may de-identify your Personal Data so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual.

Analytics: We may use third party analytics service providers, such as Google Analytics, Mixpanel, and Flurry for our business purposes. When you use our Services, these analytics service providers may collect and retain some information about you by planting a persistent cookie or identifier on your web browser or device. Flurry is a Yahoo company and you can learn more about its privacy policy and practices here: http://www.flurry.com/privacy-policy.html. You may opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/. You may opt-out of Mixpanel’s analytics services by visiting https://mixpanel.com/optout/. Please note that if you get a new computer, install a new browser, delete or otherwise alter your browser’s cookie file (including upgrading browsers), you may clear the Mixpanel opt-out cookie. You may find additional information about Google’s ability to use and share information collected by Google Analytics by visiting www.google.com/policies/privacy/partners/. If you would like more information on the type of information Mixpanel collects, please visit Mixpanel’s Terms of Use: https://mixpanel.com/legal/terms-of-use/.

Advertisers: We may engage advertisers and/or merchant partners for marketing or promotional purposes.

Affiliated Businesses: In certain situations, businesses or third party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Data with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.

Our Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use a payment processing company to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Data we share with them beyond what is necessary to assist us.

User Profiles and Submissions: Certain user profile information, including your name, location, and any video or image content that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account privacy settings may allow you to limit the other users who can see the Personal Data in your user profile and/or what information in your user profile is visible to others. Please remember that any content you upload to your public user profile, along with any Personal Data or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments.

Business Transfers: We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Data could be one of the assets transferred to or acquired by a third party.

Protection of Company and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others.

Is Personal Data about me secure?

Your account or portions of the Service may be protected by a password for your privacy and security. If so, you must prevent unauthorized access to your account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. Our security measures vary based on the sensitivity of the Personal Data we collect, process and store and the current state of technology.

We endeavor to protect the privacy of your account and other Personal Data we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

What Personal Data can I access?

Through your account settings (if applicable), you may access, and, in some cases, edit or delete the following information you’ve provided to us:

The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at info@brimsecurity.com.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at info@brimsecurity.com.

What rights do I have regarding my Personal Data?

IF YOU ARE A RESIDENT OF THE EU, SWITZERLAND, UNITED KINGDOM, LICHTENSTEIN, NORWAY, OR ICELAND, YOU HAVE CERTAIN RIGHTS WITH RESPECT TO YOUR PERSONAL DATA, INCLUDING THOSE SET FORTH BELOW. FOR MORE INFORMATION ABOUT THESE RIGHTS, OR TO SUBMIT A REQUEST, PLEASE EMAIL INFO@LOOKY.CLOUD. PLEASE NOTE THAT IN SOME CIRCUMSTANCES, WE MAY NOT BE ABLE TO FULLY COMPLY WITH YOUR REQUEST, SUCH AS IF IT IS FRIVOLOUS OR EXTREMELY IMPRACTICAL, IF IT JEOPARDIZES THE RIGHTS OF OTHERS, OR IF IT IS NOT REQUIRED BY LAW, BUT IN THOSE CIRCUMSTANCES, WE WILL STILL RESPOND TO NOTIFY YOU OF SUCH A DECISION. IN SOME CASES, WE MAY ALSO NEED YOU TO PROVIDE US WITH ADDITIONAL INFORMATION, WHICH MAY INCLUDE PERSONAL DATA, IF NECESSARY TO VERIFY YOUR IDENTITY AND THE NATURE OF YOUR REQUEST.

How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to info@brimsecurity.com, and we will try to resolve your concerns.