Last updated: 31 July 2023
This information explains how BRIGHT Products might collect, store, use and/or share (“process”) any information you give to us when you:
- Engage with us in other related ways, including any sales, marketing, or events
and the ways in which we protect your privacy. We are committed to protecting your privacy. We will not share your information with others without your prior consent.
1.1 ‘Personal data’ means information which relates to a living person who can be identified from that data (a ‘data subject’) on its own, or when taken together with other information which is likely to come into our possession. It includes any expression of opinion about the person and an indication of the intentions of us or others, in respect of that person. It does not include anonymised data.
1.2 BRIGHT Products AS is a “data controller”for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data.
1.3 BRIGHT Products AS may engage a “data processor”. This is any party which processes personal data on behalf of BRIGHT Products AS
2.1 BRIGHT Products AS is committed to protecting the privacy and security of your personal data, and complying with all applicable data protection law.
2.2 This policy applies to all personal data whether it is stored electronically, on paper or on other materials.
2.3 If you are a customer we may collect and use the following personal data: your contact details; the content of any correspondence; your address; and your order history.
2.4 If you are a job applicant we may collect and use the following personal data: Application form; Contact details; CVs; Correspondence; Interview notes; and Details of any other pre-employment assessments.
3) How we define processing
3.1 ‘Processing’ means any operation which is performed on personal data such as: collection, recording, organisation, structuring or storage; adaption or alteration; retrieval, consultation or use; disclosure by transmission, dissemination or otherwise making available; alignment or combination; and restriction, destruction or erasure. This includes processing personal data which forms part of a filing system and any automated processing.
4) How will we process your personal data?
4.1 BRIGHT Products AS Ltd will process your personal data in accordance with our obligations under applicable data protection law.
4.2 We will use your personal data for: performing the contract to supply services complying with any legal obligation; or to pursue our legitimate interests (or the legitimate interests of someone else). However, we can only do this if your interests and rights do not override ours (or theirs). You have the right to challenge our legitimate interests and request that we stop this processing. See details of your rights in section 7 below. We can process your personal data for these purposes without your knowledge or consent. We will not use your personal data for an unrelated purpose without telling you about it and the legal basis that we intend to rely on for processing it. If you choose not to provide us with certain personal data you should be aware that we may not be able to carry out certain parts of the contract between us. For example, if you do not provide us with your address we will be unable to supply any purchased goods. It might also stop us from complying with certain legal obligations and duties which we have.
4.3 BRIGHT Products AS will only hold data for as long as necessary for the purposes for which we collected it. For information on the retention periods for personal data contact: firstname.lastname@example.org
5) Examples of when we might process your personal data
5.1 We have to process your personal data in various situations.
5.2 For example for customers: To deliver orders; To deal with any enquiries relating to products, or any complaints; and To comply with tax law, or any other laws which affect us.
5.3 For example for job applicants: To determine suitability and eligibility for any roles applied for; and To facilitate any communication with candidates required during a recruitment process.
5.4 We will not process any special categories of data without expressly informing you.
5.5 We do not take automated decisions about you using your personal data or use profiling in relation to you.
6) Marketing and Advertising
From time to time, we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.
Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
We will only send you marketing messages if you have given us your consent to do so. You can update your preferences about the emails you receive from us at a later date, including withdrawing your consent, by clicking on the link at the bottom of our marketing emails.
7) Sharing your personal data
We may also share your personal information with the following:
7.1 Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.
7.2 Social media: we may use “lookalike” analytics functions, such as “Facebook Lookalike Audiences”, to identify new potential customers on the basis that they might share some characteristics with you. If you interact with us through social media, we may therefore share your personal information with social media platforms to enable them to identify users similar to you, such as users that have liked the same pages or content as you.
7.3 Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
7.4 Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; exercise or protect the rights, property, or personal safety of BRIGHT Products AS or its products.
7.5 Other than as set out above, we may also share statistics and insights developed by us from your personal information. These statistics and insights are derived from anonymised and aggregated information, such that it would not be possible to identify you (directly or indirectly) or even single you out from this information.
8) Links to third party sites
The Site may, from time to time, contain links to and from third party websites, including those of our partner networks, advertisers, partner merchants, news publications, and retailers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
9) Your data subject rights
As a data subject you have access to the following rights:
9.1 You have the right to information about what personal data we process, how and on what basis. You have the right to access your own personal data by way of a subject access request. You can correct any inaccuracies in your personal data. To do so you should contact email@example.com
9.2 You have the right to request that we erase your personal data where we were not entitled under the law to process it or it is no longer necessary to process it for the purpose it was collected. To do so you should contact firstname.lastname@example.orgWhile you are requesting that your personal data is corrected or erased or are contesting the lawfulness of our processing, you can apply for its use to be restricted while the application is made. To do so you should contact email@example.com
9.3 You have the right to object to data processing where we are relying on a legitimate interest to do so and you think that your rights and interests outweigh our own and you wish us to stop. You have the right to object if we process your personal data for the purposes of direct marketing. You have the right to receive a copy of your personal data and to transfer your personal data to another data controller under certain circumstances. We will not charge for this and will in most cases aim to do this within one month.
9.4 With some exceptions, you have the right not to be subjected to automated decision-making. You have the right to be notified of a data security breach concerning your personal data. In most situations we will not rely on your consent as a lawful ground to process your data. If we do however request your consent to the processing of your personal data for a specific purpose, you have the right not to consent or to withdraw your consent later. To withdraw your consent, you should contact firstname.lastname@example.org
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11) Changes to this policy
This policy was last modified July 31, 2023.