This Privacy Policy explains how we collect, share, use, and protect information when you visit any of our websites (each a “Site”) or use any online service or other application operated or offered by Brightvine LLC or its affiliates (collectively “we” or “our”) that links to this Privacy Policy, including the Brightvine portal or communications with us offline, such as by mail, email, or telephone for customer support (each a “Service”). This Privacy Policy does not apply to information that is collected by any third-party website or service that you access through our services.
In this Privacy Policy, to “process” information means to perform any operation on the information, whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying. This Privacy Policy also does not apply to any website or service that does not display or link to this Privacy Policy.
Our Services are not intended for children under 13. We do not knowingly collect personal information from children under 13. If you believe your child has provided personal information to us, please contact us at support@brightvine.com. We will immediately delete any personal information that we believe pertains to a child.To the extent we are deemed under applicable law to provide an individual consumer financial product or Service, we will use and share personal information that we collect from or about you in accordance with our Brightvine Consumer Privacy Notice provided at the end of this policy.
If you reside outside the United States, you understand that your personal information may be processed in countries (including the United States) where laws regarding processing of personal information may be less stringent than the laws in your country.
Please read this Privacy Policy carefully. When you submit information to us, you consent to the processing of your information as described in this Privacy Policy. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, YOU MAY NOT USE THE SERVICES.
Brightvine LLC is responsible for your information under this Privacy Policy. Brightvine LLC can be reached by emailing support@brightvine.com, or writing us at 50 California, Suite 1535, San Francisco, CA 94111.
The types of personal information we collect depends on the product or Service you use. For the purposes of this Privacy Policy, personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer. Some information may be provided by you directly, while other information may be provided to us by third parties involved in a transaction in which you have an interest and that utilizes one or more of our products or services.
Account Information
The account information we may collect may include but is not limited to your name, email address, mailing address, and telephone number(s) for account verification and retrieval purposes.
Portfolio Information
The investment information we collect may include but is not limited to portfolios, buy/sell information, user details, security holdings, and tax information.
Transaction Information
The transaction information we may collect may include but is not limited to wallet ID, transaction information, transaction documents, and recipient information.
Group Information
The group information we may collect may include but is not limited to names, email addresses, and other information for individuals participating in an account group.
Usage Information and Other Information
When you visit our Sites or use our online services, we may collect and aggregate usage information to help us understand how people view the Site so that we can improve its usefulness and value over time. When you use our online services, we may collect information to better provide the services to you and optimize your user experience. We may also collect data that helps us monitor network traffic and identify unauthorized or unusual activity.
The specific information we may collect includes: the name of the domain and host used to access the Internet (e.g., gmail.com); internet protocol (IP) address of the host server; referring page; name and version of the Web browser; date, time and country of Site access; internet address of any Site viewer used to link to our Site; page views and length of time on each page.
If you request materials or send an inquiry, we may collect your name, email address, company name and title, and any other information that you send to us in such communication.
Additional Sources of Information
We may also collect information about you from additional sources, including without limitation, third party sources such as our business clients, government agencies, consumer reporting agencies, and other commercially available suppliers of information. Such information may include your name, address, job role, public employment profile, credit history, status on any sanction lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to assess risk and ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contractual obligations with you and others.
We may combine this information with the personal and other information we have collected about you. When the combined information directly or indirectly identifies an individual, we treat it as personal information.
We may analyze public blockchain data to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms, and to analyze transaction trends for research and development purposes.
We use your personal information as follows:
Account Information
We use Account Information to verify your identity, create, and administer your account. We also use Account Information for purposes of preventing fraud and enhancing the security of your account or our Services, responding to your requests, communicating with you, and managing your preferences,
Portfolio Information
We use your Portfolio Information for our internal business purposes, to process and service your account, to effect transactions you request, and share information as you direct, for example to potential buyers of your assets that you invite to offering(s) or to other parties that you invite to view your portfolio.
Transaction Information
We use your Transaction Information for internal business purposes, to process and service your account, to effect transactions you request, and share information as you direct. Depending on your account settings, other users may be able to view your Transaction Information.
Group Information
We use your group information for account administration and for our internal business purposes.
Usage Information and Other Information
We use Usage Information and other personal information for:
We may also use information that we collect or produce, including personal information, on an aggregate basis, such that it does not identify any individual customers, for various business purposes at our discretion. If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your personal information.
We may share the information we collect from and about you with our related affiliates and other third parties. For example, we may share your information with:
Applicable law may require Brightvine to disclose your personal information if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant) or other legal requirements; (ii) necessary to protect legal rights of Brightvine users, customers, business partners, or other interested parties; or (iii) necessary for the prevention or detection of crime.
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many websites, including ours, do not respond to DNT signals.
We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss. We restrict access to your information to those employees who need to know that information to perform their job functions.
Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure. We expect that you will use appropriate security measures to protect the personal information you transmit to us.
You are responsible for maintaining the security of your account and the information in your account. We may suspend your use of all or part of our services without notice if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address on record on your account.
If you believe that your account or information is no longer secure, please notify us immediately at support@brightvine.com.
We will retain your personal information for the period necessary to provide Services you request and fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include but is not limited to:
Device permissions. Mobile Device operating systems have permission systems for specific types of device data, such as location services, and so-called push notifications. You can change your settings on your Device to consent or decline the collection of data or the display of the notifications, but certain services may lose full functionality when you do. You also can stop all information collection by our mobile application by uninstalling it from your Device.
If you would like to (i) review, correct, update, or delete personal information about you that you have previously provided to us, (ii) restrict our processing of your personal information, or (iii) receive an electronic copy of your personal information for purposes of transmitting it to another company (if these rights are provided to you by law), please contact us at support@brightvine.com.
In your request, please make it clear the personal information to which your request relates and the actions you would like us to take. For your protection, we will verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we often need to retain certain personal information for recordkeeping purposes and our databases and other records may have residual data that we will not remove. We also may not allow you to review or delete certain data for legal, security or other reasons. If required by applicable law, we will sever the link between your identity and the blockchain history of transactions involving you.
If at any time you believe that the services have not adhered to this Privacy Policy, please let us know. We will use good faith efforts to determine and correct the problem.
“Cookies” are small pieces of information that a website stores on your computer while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (most of which have an expiration date, based on the purpose of the cookie, at which point they self-delete). We may place two kinds of cookies: essential and performance/analytics (non-essential).
a) Essential Cookies. These cookies are strictly necessary to provide you with the Site and Services available through our Site and to use some of its features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Site, you cannot refuse them without impacting how our Site functions.
b) Non-Essential Cookies. We may use two kinds of non-essential cookies: performance or advertising. You may opt into or out of non-essential cookies using the cookie banner on the Site. Non-essential performance cookies help us analyze how the Site is being accessed and used, enable us to track performance, and secure the Site. For example, we use those cookies to get insights regarding users and Site performance, such as page speed or to help us customize our Site and services for you in order to enhance your experience.
c) Uses. We generally use cookies and similar technologies as follows:
d) Opting Out.
If you’d like to remove or disable cookies via your browser, refer to your browser’s settings. Most advertising networks offer you a way to opt out of interest-based advertising. If you wish to limit third parties’ collection of information about your use of our Site, you can opt out at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. You may still see non-targeted advertising on other sites.
e) Changing your marketing preferences.
You may ask us not to process your information for marketing purposes and can exercise the right at any time by sending us an email at support@brightvine.com or by clicking on 'unsubscribe' in any of our marketing emails.
The services may include links to third-party websites and services that are not operated by us. When you click on these links, you will be directed away from the services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. This Privacy Policy does not apply to any personal information that you provide to these other websites and services.
The “Last Updated” date of this Privacy Policy is set forth at the top of this webpage. As we add new features to our services, we may amend this Privacy Policy. If we make a material change to this Privacy Policy that reduces your privacy rights, we will notify you in advance through our Services. Your continued use of the Services after the Last Updated Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.
If you have any questions about this privacy policy, the practices of this Site, or your dealings with this Site, please contact us at Info@brightvine.com.
Facts
What Does Brightvine Do With Your Personal Information?
Why?
Companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?
The types of personal information we collect and share depend on the product or service you have with us. This information can include, without limitation:
You consent to our collection, transfer, and storage of information by computers or other transfer or storage devices in the United States and elsewhere when you supply information.
When?
This Privacy Notice was last modified on the Last Updated date set forth above.
How?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, the reasons Brightvine chooses to share, and whether you can limit this sharing.
Brightvine does not sell personal information.
Reasons We Can Share Your Personal Information
Does Brightvine Share?
Can You Limit This Sharing?
For Our Everyday Business Purposes
Such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
Yes
No
For Our Marketing Purposes
To offer our products and services to you
Yes
Yes
For Joint Marketing With Other Financial Companies
Yes (with your prior consent)
Yes
For Our Affiliates’ Everyday Business Purposes
Information about your transactions and experiences
Yes
No
For Our Affiliates’ Everyday Business Purposes
Information about your creditworthiness
No
We Do Not Share
For Our Affiliates to Market to You
To offer their non-financial products, or financial products not involving personal credit or personal insurance
No
We Do Not Share
For Our Affiliates to Market to You
To offer personal credit or personal insurance products to you
No
We Do Not Share
For Non-Affiliates to Market to You
No
We Do Not Share
To Limit Our Sharing
If you prefer that we limit sharing with affiliates or nonaffiliated third parties as described above, you may opt out of those disclosures as follows: Call us at (628)222-4643 or email us at support@brightvine.com.
Note: If you are a new consumer or customer, we can begin sharing your information 30 days from the date of this Privacy Notice. When you are no longer our consumer or customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
Questions
Call (628) 222-4643 or Email support@brightvine.com.
Who We Are
Who is Providing This Notice?
Brightvine LLC and the affiliated family of Brightvine companies comprised of our U.S. legal entities with the Brightvine name.
What We Do
How does Brightvine protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We endeavor to limit personal information access to only employees, agents and representatives that need to know, and we require companies that work for us to protect your information.
How does Brightvine collect my personal information?
We collect your personal information, for example, when you:
Why can’t I limit all sharing?
Federal law gives you the right to limit only:
State laws and individual companies may give you additional rights to limit sharing.
What happens when I limit sharing for an account I hold jointly with someone else?
Your choices will apply to everyone on your account.
Definitions
Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include companies with the Brightvine name, including financial or insurance companies such as Brightvine LLC and Brightvine Securities LLC, and non-financial companies such as Brightvine Holding Company LLC.
Non affiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates we share with can include financial services companies and nonfinancial companies such as lifestyle products and services companies and membership clubs.
Joint Marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners can include financial service companies and insurance companies.
Other Important Information
EXTERNAL WEBSITES
Our Site may be linked to or from third party websites. We are not responsible for the content or privacy practices of websites that are linked to or from our Site.
CHANGES
We reserve the right to modify this Privacy Notice. You can get updated Privacy Notices by visiting our Site at www.brightvine.com.