Brassica Technologies Inc collects some Personal Data from its Users.
This document contains a section dedicated to Californian consumers and their privacy rights.
This document contains a section dedicated to Brazilian Users and their privacy rights.
This document can be printed for reference by using the print command in the settings of any browser.Owner and Data Controller
Brassica Technologies Inc. 3040 Post Oak Blvd, Suite 1800-165 Houston, TX 77056
Owner contact email: email@example.comTypes of Data collected
Among the types of Personal Data that Brassica Technologies Inc collects, by itself or through third parties, there are: Tracker; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); payment info; first name; last name; email address; billing address; purchase history; various types of Data; Data communicated while using the service; mouse movements; motion sensor events; answers to questions; Data communicated in order to use the Service; scroll position; keypress events; touch events.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Brassica Technologies Inc.
Unless specified otherwise, all Data requested by Brassica Technologies Inc is mandatory and failure to provide this Data may make it impossible for Brassica Services, LLC to provide its services. In cases where Brassica Services, LLC specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through Brassica Technologies Inc and confirm that they have the third party's consent to provide the Data to the Owner.Mode and place of processing the Data Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Brassica Technologies Inc (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; processing is necessary for compliance with a legal obligation to which the Owner is subject; processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner; processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed. Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Tag Management, Analytics, Handling payments, Contacting the User, Displaying content from external platforms, Hosting and backend infrastructure, Collection of privacy-related preferences, Infrastructure monitoring, SPAM protection, Data transfer outside of the UK, Managing contacts and sending messages, Managing support and contact requests, Operations and Handling compliance.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.Google Analytics (Google LLC)
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Brassica Technologies Inc, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Category of personal information collected according to CCPA: internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Google Analytics Demographics and Interests reports (Google LLC)
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for Brassica Technologies Inc (demographics means age and gender Data).
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Category of personal information collected according to CCPA: identifiers; internet information.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.Collection of privacy-related preferences
This type of service allows Brassica Technologies Inc to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.iubenda Consent Solution (iubenda srl)
The iubenda Consent Solution allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent. In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.
Personal Data processed: Data communicated while using the service; Tracker.
Category of personal information collected according to CCPA: internet information.iubenda Cookie Solution (iubenda srl)
Category of personal information collected according to CCPA: internet information.Contacting the User Contact form (Brassica Technologies Inc)
By filling in the contact form with their Data, the User authorizes Brassica Technologies Inc to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: email address; first name; last name; various types of Data.
Category of personal information collected according to CCPA: identifiers; internet information.Data transfer outside of the UK
The Owner is allowed to transfer Personal Data collected within the UK to third countries only subject to specific legal requirements (so-called "restricted transfers"). Restricted transfers may take place according to the conditions specified below.
Users can enquire with the Owner to learn which legal basis applies to which specific service.Data transfer abroad based on consent (UK) (Brassica Technologies Inc)
If this is the legal basis, Personal Data of Users shall be transferred from the UK to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via Brassica Technologies Inc.
Personal Data processed: various types of Data.
Category of personal information collected according to CCPA: internet information.Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Brassica Technologies Inc and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.Google Fonts (Google LLC)
Identity verification and screeningHandling payments
Unless otherwise specified, Brassica Technologies Inc processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Brassica Technologies Inc isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.Stripe (Stripe Inc)
This type of service has the purpose of hosting Data and files that enable Brassica Technologies Inc to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Brassica Technologies Inc.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.Amazon Web Services (AWS) (Amazon Web Services, Inc.)
This type of service allows Brassica Technologies Inc to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved. Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Brassica Technologies Inc.Datadog (Datadog, Inc.)
Category of personal information collected according to CCPA: internet information.Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.SparkPost (Message Systems, Inc.)
This type of service allows Brassica Technologies Inc to manage support and contact requests received via email or by other means, such as the contact form. The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).Zendesk (Zendesk, Inc.)
Encrypted, electronic storage of filesDocusign
Electronic signature captureIndustry Third Parties
Brassica Services is authorized to make certain data available to industry third-party systems, both directly and via API integrations, including but not limited to broker-dealers, investment advisers, securities exchanges, rating agencies, research firms and others for purposes of enabling them to obtain information about and descriptions of Issuer’s Securities, payment history of such Securities, confirmations of a holder’s ownership positions, holder information, and enforcing restrictions on any proposed divestitures (including ownership changes).SPAM protection
This type of service analyzes the traffic of Brassica Technologies Inc, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.hCaptcha (Intuition Machines, Inc)
This type of service helps the Owner to manage the tags or scripts needed on Brassica Technologies Inc in a centralized fashion. This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.Segment (Segment Inc.)
Users may exercise certain rights regarding their Data processed by the Owner.In particular, Users have the right to do the following:Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.How to exercise these rights
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Brassica Technologies Inc or the related Services.The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.Additional information about User's Personal Data
For operation and maintenance purposes, Brassica Technologies Inc and any third-party services may collect files that record interaction with Brassica Technologies Inc (System logs) use other Personal Data (such as the IP Address) for this purpose.Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.How “Do Not Track” requests are handled
In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.Information we collect: the categories of personal information we collect
We have collected the following categories of personal information about you: identifiers, commercial information, internet information and inferred information.We will not collect additional categories of personal information without notifying you.How we collect information: what are the sources of the personal information we collect?
We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use Brassica Technologies Inc.For example, you directly provide your personal information when you submit requests via any forms on Brassica Technologies Inc. You also provide personal information indirectly when you navigate Brassica Technologies Inc, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of Brassica Technologies Inc and features thereof.How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose
We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.To find out more about the purposes of processing, please refer to the relevant section of this document.Sale of your personal information
For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.Your right to opt out of the sale of personal information
You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.Instructions to opt out of the sale of personal information
If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by Brassica Technologies Inc, both online and offline, you can contact us for further information using the contact details provided in this document.What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of Brassica Technologies Inc and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.Your California privacy rights and how to exercise them The right to know and to portability
You have the right to request that we disclose to you:the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:for sales, the personal information categories purchased by each category of recipient; andfor disclosures for a business purpose, the personal information categories obtained by each category of recipient.The disclosure described above will be limited to the personal information collected or used over the past 12 months.If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on Brassica Technologies Inc, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.How to exercise your rights
To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.You can submit a maximum number of 2 requests over a period of 12 months.How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.Our disclosure(s) will cover the preceding 12 month period.Should we deny your request, we will explain you the reasons behind our denial.We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.Information for Users residing in Brazil
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:your consent to the relevant processing activities;compliance with a legal or regulatory obligation that lies with us;the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;studies conducted by research entities, preferably carried out on anonymized personal information;the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;the exercising of our rights in judicial, administrative or arbitration procedures;protection or physical safety of yourself or a third party;the protection of health – in procedures carried out by health entities or professionals;our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; andcredit protection.To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.Your Brazilian privacy rights, how to file a request and our response to your requests Your Brazilian privacy rights
You have the right to:obtain confirmation of the existence of processing activities on your personal information;access to your personal information;have incomplete, inaccurate or outdated personal information rectified;obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;obtain information on the possibility to provide or deny your consent and the consequences thereof;obtain information about the third parties with whom we share your personal information;obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions are provided for in art. 16 of the LGPD apply;revoke your consent at any time;lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;request clear and adequate information regarding the criteria and procedures used for an automated decision; andrequest the review of decisions made solely on the basis of the automated processing of your personal information, which affects your interests. These include decisions to define your personal, professional, consumer, and credit profile, or aspects of your personality.You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.How and when we will respond to your request
We will strive to promptly respond to your requests.In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves a disproportionate effort on our side.Transfer of personal information outside of Brazil is permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;when the transfer is necessary to protect your life or physical security or those of a third party;when the transfer is authorized by the ANPD;when the transfer results from a commitment undertaken in an international cooperation agreement;when the transfer is necessary for the execution of a public policy or legal attribution of public service;when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.Definitions and legal referencesPersonal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.Usage Data
Information collected automatically through Brassica Technologies Inc (or third-party services employed in Brassica Technologies Inc), which can include: the IP addresses or domain names of the computers utilized by the Users who use Brassica Technologies Inc, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.User
The individual using Brassica Technologies Inc who, unless otherwise specified, coincides with the Data Subject.Data Subject
The natural person to whom the Personal Data refers.Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Brassica Technologies Inc. The Data Controller, unless otherwise specified, is the Owner of Brassica Technologies Inc.Brassica Technologies Inc (or this Application)
The means by which the Personal Data of the User is collected and processed.Service
The service provided by Brassica Technologies Inc as described in the relative terms (if available) and on this site/application.European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.Legal information