Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights under applicable laws and how to exercise such rights.

By using or submitting information through the Service, You agree to the terms of this Privacy Policy and consent to Our collection, use, disclosure and retention of information in accordance with this Privacy Policy.

If you are a California resident and a Company employee, job applicant or independent contractor, please see Our CPRA Employee / Applicant / Independent Contractor Notice (“Employee Notice”), which applies to Our Processing of your Personal Information as it relates to the employment relationship.

Interpretation and Definitions

INTERPRETATION
The capitalized terms in this Privacy Policy, unless otherwise stated herein, shall have the following meanings. Capitalized terms not otherwise defined in this Privacy Policy shall have the meaning given to them under applicable law, including the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (“CPRA”).The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

DEFINITIONS
For the purposes of this Privacy Policy:

• You the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Bright Sky Group of Services on behalf of itself and its affiliates and subsidiaries.
• Website refers to any of the websites and/or mobile applications We operate and control, including but not limited to  https://brightskyinc.com.
• Service refers to the Website and other offline methods for which We provide Our services.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals engaged by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Third-party Social Media Service refers to any website or any social network website through which a user can log in or create an account to use the Service.
• Facebook Fan Page is a public profile named Bright Sky Group of Services specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/BrightSkyGroupofServices.
• Personal Data is any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You. Personal Data does not include publicly available information or truthful, lawfully obtained information that is a matter of public concern.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website or an online service when you visit the website or online service. When you visit the website or use the online service again, the Cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information such as the details of Your browsing history on that website or online service among its many uses.
• Usage Data refers to data collected automatically, either generated by the access or use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Sale, Sell, Sold or Selling for the purpose of the CPRA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Data to another business or a third party for monetary or other valuable consideration.
• Share, Shared or Sharing for the purpose of the CPRA means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Data to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.

Collecting and Using Your Personal Data

TYPES OF DATA COLLECTED
Personal Data
While using Our Service, We may ask You to provide Us with certain Personal Data. Such Personal Data may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address
• Usage Data
• Any other information you may provide us when using the chat functionality on the Website.

Usage Data
Usage Data is collected automatically when using the Website.

Usage Data may include information such as Your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Website by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Website or when You access the Website by or through a mobile device.

Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Website.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

We use both session and persistent Cookies for the purposes set out below:

• Necessary/Essential Cookies. Type: Session Cookies. Administered by: Us. Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
• Functionality Cookies. Type: Persistent Cookies. Administered by: Us. Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.
• Tracking and Performance Cookies. Type: Persistent Cookies. Administered by: Third-Parties. Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Site.

We may use third-party Service Providers to monitor and analyze the use of our Website.

• Facebook Insights. We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and to obtain anonymized statistical data about Our users. For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.For more information on the privacy practices of Facebook, please visit the Facebook Privacy Policy.
• Google Analytics.Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.
• LinkedIn Insight Tag.We use the “LinkedIn Insight Tag” of LinkedIn Corporation (“LinkedIn”) on our Website. It helps us with in-depth campaign reporting and insights about our Website visitors. It can also be used to track conversions, retarget website visitors, and unlock additional insights about members interacting with our ads on LinkedIn.
  The LinkedIn Insight Tag enables the collection of data regarding members’ visits to our Website, including the URL, referrer, IP address, device and browser characteristics (User Agent), and timestamp. This data is encrypted, the IP addresses are truncated, and members’ direct identifiers are removed to make the data pseudonymous.LinkedIn does not share Personal Data with us, it only provides aggregated reports about the Website audience and ad performance. LinkedIn also provides retargeting for Website visitors, enabling us to show personalized ads off our Website by using this data, but without identifying the member. LinkedIn members can control the use of their Personal Data for advertising purposes through their account settings.All this is in accordance with LinkedIn terms and cookie policies.

USE AND DISCLOSURE OF YOUR PERSONAL DATA
The Company may use and disclose Personal Data for one or more of Our business or commercial purposes, including:

• To provide and maintain our Service, including to help Us provide, operate, maintain, evaluate, and improve the Service and its quality, monitor the usage of our Service, better understand Our users and their interactions with the Service, for customer service and/or support, security (including for authentication purposes), to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Website.
• For our internal business purposes: We may use Personal Data as needed to support external auditing, compliance and corporate governance functions.
• To manage Your account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: for the development, compliance and undertaking of the contract for Our services You have requested or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, through the chat function on the Website, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To manage Our relationship with You: To provide important changes to Our terms, conditions, policies, and other administrative information, or to provide You with news, special offers and general information about other services which we offer that are similar to those that you have already requested or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• To comply with applicable laws and protect our rights: We may use Personal Data as We believe to be necessary or appropriate under applicable law, to comply with legal process, to respond to requests from public and government authorities, to enforce this Privacy Policy, to protect our operations or those of any of Our affiliates and subsidiaries, to protect Our rights, privacy, safety or property, and/or that of our affiliates and subsidiaries, you, or others, to prevent or investigate possible wrongdoing in connection with the Service, and to allow us to pursue available remedies or limit the damages that we may sustain.
• With your consent: We may collect, use, and disclose your Personal Data for any other business purpose for which you provide consent.

We may share your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with Service Providers to perform the functions for which we engage them. For example, we may engage Service Providers to monitor and analyze the use of our Website, to host the Website or assist us in providing functionality on the Website, provide a chat function on the Website or to contact You.
• For Business transfers: We may share, assign or transfer Your Personal Data in connection with, or during negotiations of, a corporate transaction, such as any merger, sale of Company assets, financing, corporate divestiture, reorganization, or acquisition of all or a portion of Our business to another company of if We undergo liquidation or bankruptcy proceedings.
• With Affiliates and Subsidiaries: We may share Your information with Our affiliates and subsidiaries , for Our internal business purposes, in which case we will require those affiliates to honor this Privacy Policy.
• With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see You name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
• For Legal Purposes: We may share Personal Data as We believe to be necessary or appropriate under applicable law, to comply with legal process, to respond to requests from public and government authorities, to enforce this Privacy Policy, to protect our operations or those of any of Our affiliates and subsidiaries, to protect Our rights, privacy, safety or property, and/or that of our affiliates and subsidiaries, you, or others, to prevent or investigate possible wrongdoing in connection with the Service, and to allow us to pursue available remedies or limit the damages that we may sustain.

RETENTION OF YOU PERSONAL DATA
The Company will retain Your Personal Data only for as long as is necessary for the purposes for which such information was collected. We will also retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

SECURITY OF YOUR PERSONAL DATA
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

DISCLOSURE OF YOUR PERSONAL DATA
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

SECURITY OF YOUR PERSONAL DATA
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

“DO NOT TRACK” SIGNALS
The Website does not currently take any action when it receives a “Do Not Track” request. Do Not Track is a privacy preference that you can set in certain web browsers to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

LINKS TO EXTERNAL WEBSITES AND ONLINE SERVICES
Our Website may contain links to third party websites and online services. Any access to and use of such third-party websites and online services is not governed by this Privacy Policy but is instead governed by the privacy policies of those third-party websites and online services, and we are not responsible for the information practices of such third-party websites and online services.

SOCIAL MEDIA
Some aspects of the Website may allow you to interface with social media, such as Facebook, Instagram, Twitter and LinkedIn. We will attempt to identify these aspects of the Website to you, for example, by identifying them with the applicable third-party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services. If you interface with the Website through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services.  For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

CPRA Privacy

YOUR RIGHTS UNDER THE CPRA
If You are a resident of California, You have the following rights regarding your Personal Data under the CPRA:

• The right to Know. You have the right to request that We disclose what Personal Data We collect, use, disclose, Sell or Share. Specifically, You may request that We disclose to You the following:

• • • The categories of Personal Data We have collected about You.
    • The categories of sources from which the Personal Data is collected.
    • The business or commercial purpose for collecting or Selling or Sharing the Personal Data.
    • The categories of third parties with whom We disclose Personal Data.
    • The specific pieces of Personal Data We have collected about You.

    You may also request that We disclose to you:

    • The categories of Personal Data that We have Sold or Shared about you and the categories of third parties to whom the Personal Data was Sold or Shared, by category or categories of Personal Data for each third party to whom the Personal Data was Sold or Shared.
    • The categories of Personal Data that We disclosed about You for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
• The right to opt-out of the sale or sharing of Personal Data. You also have the right to ask the Company not to Sell or Share Your Personal Data to third parties. You can submit such a request by visiting Do Not Sell or Share My Personal Information. The Company does not have actual knowledge that it Sells or Shares Personal Data about minors under the age of 16.
• The right to delete Personal Data. You have the right to request the deletion of Personal Data We have collected from You, subject to certain limitations. If it is necessary for Us to maintain Your Personal Data for certain purposes, We are not required to comply with your deletion request. If We determine that We will not delete Your Personal Data when You request us to do so, We will inform You and tell You why We are not deleting it.
• The right to correct inaccurate Personal Data. You have the right to request that We correct any inaccurate Personal Data We maintain about You, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data.
• The right to limit use and disclosure of Sensitive Personal Data. We do not collect your sensitive Personal Data.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of aforementioned rights, including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

EXERCISING YOUR CPRA RIGHTS
In order to exercise any of Your rights under the CPRA, You must submit a verifiable request to us via email at info@brightskyinc.com, by visiting https://brightskyinc.com/contact-us/ or calling us at (630) 595-6396.

If You maintain an online account with Us, We will verify Your identity for a request through the normal account authentication process, meaning You will need to sign on with Your username and password.

To submit a verifiable request, You will be asked to provide certain information to help Us verify Your identity. The information We ask You to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the Personal Data that is the subject of the request, and the risk of harm to You that may occur as a result of unauthorized access or deletion, among other factors.

You may designate an authorized agent to make a request on Your behalf by providing the agent with signed written permission to do so.

If We cannot verify Your identity or authority to make the request, We will not be able to comply with Your request. We will inform You if We cannot verify Your identity or authority. We will only use Personal Data provided in a verifiable request to verify the requestor’s identity or authority to make the request.

The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

PERSONAL DATA COLLECTED, USED, DISCLOSED, SOLD OR SHARED
We have collected the following categories of Personal Data and used, disclosed, Sold or Shared such information in the twelve (12) months prior to the effective date of this Privacy Policy:

The Company may collect your Personal Data through the following categories of sources:

• You, directly and indirectly, including when You visit Our Website, sign up for information or mailing lists or engage in a contractual relationship with Us.
• Service Providers, including those that provide analytics services to help us understand the activity on the Website.
• Publicly available resources.

The Company collects and discloses the Personal Data described above for a variety of business purposes as described in the section entitled “Use and Disclosure of Your Personal Data” above. The Company discloses the Personal Data described above with the third parties set forth in the section entitled “Use and Disclosure of Your Personal Data” above.

As stated in the section entitled “Retention of Your Personal Data”, the Company will retain Your Personal Data only for as long as is necessary for the purposes for which such information was collected. We will also retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s “Shine the Light” law), California residents with an established business relationship with us can request information once a year, free of charge, about the Personal Data We’ve shared with third parties for the third parties’ direct marketing purposes.

To request more information under the California Shine the Light law, You can contact Us using the contact information provided below.

Children

We do not knowingly collect or maintain Personal Data from any person under the age of 16. No parts of Our Service are directed to or designed to attract anyone under the age of 16.

Nevada Law

Under Nevada law, the Company does not sell Your Personal Data. However, if You are a Nevada resident, You may submit a request that We not sell any Personal Data We have collected about you by contacting us as set forth below.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us at info@brightskyinc.com.

Effective date: April 8, 2023