Last Updated: 28 February 2024.
- Introduction and Definitions
Brize, LLC (Brize) is a digital-first continuous learning platform. We equip employees with vital skills to thrive at every career stage, whether in Strategic Presence, Managing Others, or Inspirational Leadership. Our comprehensive approach integrates assessments, educational content, strengthening exercises, live coaching, and engagement nudges to move progress forward.
We provide services to individuals directly via the Platform (“Users) and the entities who contract with us to provide Services to their employees or others on the Platform (“User Organizations”). We collect, use and share data differently for Users and User Organizations, although they might sometimes be one and the same. In the event you receive Brize Services as a result of your employer or other sponsoring organization, please be aware of the data which may be shared back to your User Organization as a result of using the Brize Platform.
We also collect data from business coaches and facilitators (“Coaches”) to provide services to Users via the Platform and from visitors (“Visitors”) to our website www.brize.co and its subdomains (the “Site”). Should you apply for a job with Brize you will be known as an “Applicant”. To the extent data is associated with an identified or identifiable natural person and is protected as personal information (or substantially equivalent terms) under applicable data protection laws, we will refer to this as “Personal Data”. Please understand that certain local laws may refer to personal information rather than Personal Data and in the context of this Policy, Brize intends these terms to be interchangeable.
- Data We Collect
2.1 Data You Provide
Data From Our Website
Data From Applicants
We collect information if you apply for a job (“Applicant”) with Brize. We will need to collect certain personal information from you in order to process your application, such as your name, email address, phone number, location, and work history. This information is used to evaluate your experience and communicate with you.
Data From Users
If you are a User, we collect data when you register for the Platform and when you access the Services via the Platform. We require certain Personal Data in order to register your account, such as:
- Your name
- Your email address
- Your phone number
- Your role or title
- Your Country and State (where applicable)
We require this data for at least the following reasons: 1) to create your account; and 2) ensure we have minimum location data to honor your specific privacy rights. If your access to the Brize Services is being provided by your User Organization, this type of data may be shared with Brize from your User Organization.
We collect data to provide and improve your experience on the Platform. For example, we may ask Users to:
- Complete an assessment that will allow you to gain insight into your approach to work
- Review your Platform experience.
- Enter your personal preferences within your User profile, such as preferred pronouns and preferred language.
Your sponsoring User Organization will never receive access to your individual questionnaires or personalization responses although they may see aggregate and de-identified reports of all Users connected to your sponsoring Organization so long as we can confirm a minimum threshold of Users from your organization to maintain anonymity.
We collect usage data from Users accessing the Platform, such as which programs you respond to and attend, when you attend a coaching circles, your employment details and any other usage data you share with us (or your User Organization shares with us) in connection with the Platform.
Your sponsoring User Organization will receive information from Brize about your usage on the Platform in the following ways:
- Individually identifiable data regarding your date of registration, number of coaching circles attended, the date you have completed certain assessments, and similar engagement level metrics.
- Aggregated and de-identified insights for topics and themes discussed by all Users associated with your sponsoring Organization as discussed within Section 4 below.
2.2 Aggregated Data from Use of Platform
We may aggregate and de-identify the data related to your use of the Platform apart from what has been detailed above. We may analyze your usage data and content when it is uploaded, sent, received, or stored. We may use your data, activity logs, and direct feedback to improve our Platform and Services.
2.3 Cookies and Similar Technologies
There is limited use of tracking technology within our Platform. We collect data from Platform Visitors such as data about your device and location via IP address, the type of browser you use, amount of time you spend on the Platform, pages viewed, forms submitted, and the digital channel that brought you to the Platform. Brize will not request precise geo-location data from our Users.
- How We User Your Data
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
Brize will use your data to drive insights and analytics to help better serve you, our Users. The primary manner in which we use all data is to provide the Services and help us improve the Site, the Platform, and the quality of our Services, and this extends to Personal Data. As described in Section 2, we request sensitive Personal Data only under very limited circumstances.
3.2 Communicate with Users
We require certain Personal Data from User for routine communication.
3.3 Market to You
We collect certain data from Site Visitors for marketing and advertising purposes. Site Visitors may also need to provide data to schedule a demo or interact with a bot on the Site to get what information you need from us more efficiently. We may also use this information to communicate with You or potentially your User Organization about product, services, offers, promotions, rewards, and events offered by Brize or others; provide news and information we think will be of interest to You or your User Organization; and deliver and measure advertisements on other media and third party websites.
3.4 Provide Customer Service
You may provide data via the Site or Platform that we use to provide a better customer support experience to you. For instance, if you were to email firstname.lastname@example.org our team would request specific information for verification purposes and as necessary to address your concerns.
- How We Share Data with Third Parties
BRIZE DOES NOT SELL YOUR PERSONAL DATA.
If you are a User who is accessing the Platform through a paid subscription through a User Organization (e.g. your employer), we share certain usage data with your sponsoring User Organization, such as data about your Platform usage (e.g. the number of coaching circles you attended, or date of completion of an assessment). We share this information with your sponsoring Organization to ensure a User Organization has the tools necessary to ensure the Services are being utilized and that they are effective. We do NOT share your questionnaire or survey responses with your User Organization. Your sponsoring Organization may see de-identified and aggregated analysis from all participating Users within your organization as aggregated from your interactions with resources within the Brize Platform. As discussed in 2.1 above, we do share limited individual level data with the sponsoring Organization.
If you are a Visitor, Coach, User or User Organization, we may also share data about you as follows:
- In response to a request for data if we believe disclosure is in accordance with any legitimate law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
- If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, to protect the rights, property, and safety of others;
- In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company; and
- With your consent or at your direction, including if we notify you through the Site, Services or Platform that certain data you provide will be shared in a particular manner and you choose to provide this data.
- Your Privacy Choices And Rights
5.1 Data Retention
We store Personal Data for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
5.2 Data Generally
You may update, correct, or delete Personal Data at any time by contacting us at email@example.com. Please note that we may retain certain data as required by law or for legitimate business purposes. We may also retain cached or archived copies of data about you for a certain period.
5.3 Email Subscriptions
You may opt out of receiving email communications from us by following the unsubscribe link within those communications or by emailing us at firstname.lastname@example.org.
5.4 Promotional Communications
If you are outside of the European Union (“EU”), you may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at email@example.com. If you opt out, we may still send you non-promotional communications specifically related to your use of the Platform.
5.5 Jurisdiction-Specific Rights
Under the General Data Privacy Regulation (“GDPR”)
If you are a resident of the European Union (EU) and European Economic Area (EEA), GDPR affords you certain rights. These include:
- The right to access, delete, or update the Personal Data we have on you
- The right to have your Personal Data rectified if it is incomplete or incorrect
- The right to object to our processing of your Personal Data
- The right to request that we restrict the processing of your Personal Data
- The right to request a copy of your Personal Data in a machine-readable and commonly used format
- The right to withdraw your consent at any time where we rely on your consent to process your Personal Data
To exercise any of the above rights, please send a request to firstname.lastname@example.org. Please note that we may ask you to verify your identity before responding to such requests.
Your Personal Data may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area.
We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States and other countries, where you might not have the same rights and protections as you do under local law. Brize may be obligated to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
You have the right to complain to a Data Protection Authority (as defined by the GDPR) about our collection and use of your Personal Data. For contact details of your local Data Protection Authority, please see here.
- California Consumer Privacy Act (“CCPA”)
If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and ask us not to sell it. You may request what personal information we have about you. If you make this request, we will return to you:
- The categories of personal information (as defined by the CCPA) we have collected about you.
- The categories of sources from which we collect your personal information.
- The business or commercial purpose for collecting or selling your personal information.
- The categories of third parties with whom we share personal information.
- The specific pieces of personal information we have collected about you.
- A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
- A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
If you request we delete your data pursuant to the CCPA, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through deidentification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.
We will not discriminate against you under any circumstances for exercising your rights in connection with the CCPA. To exercise your California data protection rights described above, please send a request to email@example.com.
- Other Information
6.1 Children’s Privacy
We do not intentionally collect any data from persons under the age of 18 (each a “Child”). If you believe that Brize may have directly collected Personal Data about a Child and wish to have us remove that Personal Data, please contact us at firstname.lastname@example.org to let us know. We’ll work with you to make sure that data is removed from our Site and Services, as applicable. In the event that Brize discovers we may have collected Personal Data about a Child, we will proactively remove that information.
6.2 Data Controller or Data Processor
Certain data protection laws distinguish between data processors and data controllers, depending on how the data is collected and shared. Brize is a Controller and a Business with respect to our direct relationship with Users within our Platform. Brize may also be a Processor with respect to data provided by a User Organization when registering on behalf of Users it is contracting for.
8505 Redwood Drive
Vienna, VA 22116