Effective Date: May 1, 2019

At Brivo®, privacy and security are core elements of our service. Accordingly, we are always conscious and respectful of the privacy and confidentiality of individuals who visit Brivo’s websites (“Visitors”). Brivo Systems LLC and its subsidiaries are collectively referred to herein as “Brivo”.

This Privacy and Security Policy (the “Privacy Policy”) describes Brivo’s privacy practices in relation to general business practices and the use of the Company’s websites (collectively, the “Site”). By visiting the Site and/or providing us with your personal information, you consent to the collection, processing, and storage of your personal information as described in this Privacy Policy. For any personal information that we receive from customers through their use of our Brivo Systems and services, see our separate Brivo Services Privacy Statement at the following link https://www.brivo.com/services-privacy/.

 

The Site may contain links to other websites. The privacy statements of those websites govern the information practices and the content of those websites. Brivo encourages you to review the privacy statements of other websites to better understand their information practices.

This Privacy Policy applies to the following:This Privacy Policy applies to the following: 

●  Personal information we collect through the Site. 

●  Personal information we collect about you in the course of interacting with you, such as when you engage with us as a customer, potential customer, vendor, service provider, potential partner, partner, applicant, consultant, contractor or other third party in relation to the operation of our business generally. This includes sales, marketing, business contact and/or registration activities conducted by Brivo.

 

Collectively this is considered “Visitor Data”.

Collection and Use of Visitor Data

Information you voluntarily provide us:

Brivo only collects the personal information necessary to enable us to respond to your requests for our products and services. When you use our Site, complete forms, schedule a demo, respond to a survey, complete a partner application, contact us or otherwise interact with our business, we usually collect personal information such as your name, e-mail address, postal address, company name, telephone number and any other information you choose to optionally provide that will enable us to respond as requested to you.

You can opt out of providing personal information by not entering it to the Site or otherwise not providing it if asked.

Information which we collect automatically:

When using the Site, we collect information through the use of commonly used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on our Site, such as the pages viewed and the links clicked. The information we collect from our Site (such as domain name, number of hits, pages visited, and length of user session) may be combined to analyze how our websites are used and how they can be improved. In some instances, we use cookies to collect information in connection with future visits from our Site, to recognize you as a previous visitor, or to track your activity on our Site.

We do not deliver third party online advertisements on our Site, but we may use third-party advertising companies to serve ads for our services when you access and use other websites, based on the information relating to your access to and use of our Site, as well as information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser during your visit to the Site.

You do not need to have the ability to accept cookies turned on in your browser to visit our Site. You can optionally refuse cookies by setting your browser 1) to decline them automatically or 2) to give you the choice of declining or accepting the placement of cookies from the Site.

Google Analytics is a web analysis service provided by Google that utilizes cookies to monitor web-traffic on our Site. We use Google Analytics to collect, track and examine data about the Site’s usage. We may run reports based on the data we collect and we may share the data with other Google services. Google may use the data to personalize and customize the advertisements that are served to you from its advertising network. The Site does not respond to Do Not Track Signals from browsers.

We only use your information as permitted by applicable law. We may combine information that we collect with information from external sources. We may use your information to:

  • Promote use of our services to you and others or to send you marketing materials
  • Distribute subscribed news and information notices to enrolled email addresses (including a link to unsubscribe)
  • Obtain your feedback on our Site
  • Statistically analyze user behavior and activity and to improve the Site or services
  • To communicate with you and provide customer support
  • Obtain your consent for a specific use

Who We Share Your Information With
Brivo may share or transfer information you provide to us or that we collect on the Site.

Business-related transfers. Brivo may share your information to other businesses that we acquire, are acquired by, or with which we merge or partner.

Service Providers. We may transfer information to third parties with whom we contract to support our activities, including maintaining and managing our end-user information.

Compliance with Laws. Brivo may determine that we need to share your information with law enforcement or other governmental authorities in order to comply with law or the legal process.

Protect Our Rights. Brivo may share your information to protect our rights and property. For example, we may share information if we believe it will prevent the misuse or unauthorized use of the Site, protect the personal safety or property of our users or the public, or in the event of bankruptcy proceedings.

 

Data Location and Safeguards
Brivo stores all Visitor Data in the continental United States. Brivo maintains a comprehensive, written information security program that contains industry standard, administrative, technical, and physical safeguards designed to prevent unauthorized access to Visitor Data. However, because no security measures are perfect or impenetrable, we cannot guarantee the security of information you submit to us.

 

Data Retention
Brivo retains Visitor Data in accordance with our data retention policies and practices. The length of time we keep your information depends upon a number of factors, including the type of information. In general, we retain personal information for as long as we have an ongoing business need to retain it. Following that period, we will delete it.

 

Data Incidents
If Brivo becomes aware of any improper access, unauthorized use or disclosure of Visitor Data (a “Data Breach”), Brivo will analyze the facts of the Data Breach in the context of applicable laws, regulations, policies and contractual obligations to determine the appropriate notification process. Brivo will conduct notifications in a timely manner after becoming aware of a Data Breach and take commercially reasonable steps to minimize harm and mitigate further risks to Visitor Data.

 

Privacy Shield Commitment
Brivo complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Brivo has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

 

U.S. Federal Trade Commission enforcement
Brivo’s commitments under Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

 

Dispute Resolution
In compliance with the Privacy Shield Principles, Brivo commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Brivo at: [email protected] or by calling us at +31​ ​20​ ​8880980 (The Netherlands) or + 1 301 664 5242 (USA).

Brivo has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States and around the world. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. If neither Brivo nor our dispute resolution provider resolves your complaint, you may have the possibility to engage in binding arbitration through the Privacy Shield Panel.

Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For additional information please go to the Privacy Shield website at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

 

Users from the European Economic Area
Legal Basis for Processing. If you are an individual resident in the European Economic Area (“EEA”), we collect and process information about you only where we have a legal basis for doing so under applicable European Union laws. The legal basis depends on how you use the Site:

  • We need to collect and use the information to provide our services to you;
  • It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests; or
  • You give us consent to do so for a specific purpose.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the services.

How to Access or Control Your Information – The General Data Protection Directive (“GDPR”) grants individuals residing in the EEA certain rights with respect to their information. These include the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. You can exercise these rights by contacting us at the address in the Contact Section below.

The GDPR provides that we may limit or deny your requests in certain cases. For example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we have compelling legitimate interests to keep, including as required by law. You may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed if you have concerns about your rights.

 

Other International Users
The Site is hosted in the U.S. If you are a consumer accessing the Site from Asia, or any other region with laws or regulations governing personal data collection, use and disclosure that differ from U.S. laws, your continued use of the Site, which is governed by U.S. law and these terms, indicates your consent to transfer of your information to the U.S.

 

Children’s Privacy
Because protecting the privacy of young children is especially important, we do not knowingly collect or maintain information from or about persons under 13 years of age. No part of our Site is structured to attract anyone under 13. If you are under 13, do not use or access the Site at any time or in any manner. If we learn that personal information of persons under 13 has been collected on the Site without verified parental consent, we will take appropriate steps to delete this information.

 

Contact Information
If you have questions regarding this Privacy Policy or if you need to request access to or update, change or removal of personal information that we control, you can do so by contacting:

Brivo Privacy Officer
Brivo Systems LLC
7700 Old Georgetown Road, Suite 300
Bethesda MD, 20814 USA
[email protected]
+1 301-664-5277

 

YOUR CALIFORNIA PRIVACY RIGHTS (FOR CALIFORNIA RESIDENTS ONLY)

Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of customers’ personal information with third parties. These businesses are required to accept requests for disclosures of these policies from customers but are only required to honor one request per calendar year. Businesses have thirty (30) days to respond to each inquiry to the designated address. Each inquiring customer will receive an explanation of the categories of customer information shared and the names and addresses of any third-party businesses. In limited circumstances, customers’ failure to submit requests in the manner specified will not require a response from the business.

If you are a California resident, you may request such information from us by sending a letter to the address listed below. In your letter, please provide your name, address and email address, as well as a request that we provide such information to you, by using the following or similar language, “I request that Brivo provides its third-party information sharing disclosures required by section 1798.83 of the California Civil Code.”

 

Brivo Privacy Officer
Brivo Systems LLC
7700 Old Georgetown Road, Suite 300
Bethesda MD, 20814 USA
[email protected]
+1 301-664-5277

 

Changes to this Privacy and Security Policy

 

Brivo reserves the right to change this Privacy Policy from time to time but will alert you that changes have been made by indicating on this Privacy Policy the date it was last updated. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our Site or by contacting you using the email address you provided. We encourage you to periodically review this Privacy Policy to stay informed about our collection, processing and sharing of Visitor Data.