SmartASSessories Privacy Policy
Last Updated: January 20, 2024
This “Privacy Policy” describes the privacy practices of SmartAssessories (“Company,” “we,” “us” and “our”) in connection with the website, located at www.brilliant.co (the “Site”) and online and offline services (including our retail stores) (“Services”), and the rights and choices available to individuals with respect to their information.
Table of Contents
How to Contact Us
If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, please contact us at the following address, email or phone number:
SmartAssessories
1720 Epps Bridge Pkwy
Ste. 108-243
Athens, GA 30606
Contact Us: Trey@Smartassessories.com
A Note About Children
The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us.
A Note to Users Outside of the United States
If you are a non U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to require that your data is treated securely and in accordance with this Privacy Policy.
Personal Information We Collect
Information You Provide to Us. Personal information you may provide to us through the Site or Services or otherwise communicate to us may include:
Information You Provide to Social Media Platforms. We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing or your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
If you choose to login to the Services via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Services, we may collect information from that platform or network. For example, this information may include your Facebook username, user ID, profile picture, cover photo, and networks to which you belong (e.g., school, workplace). You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address. You can read more about your privacy choices in the “Third-party platforms or social media networks” portion of the “Your Choices” section below.
Information Collected via Technology. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Sites and other online services. The information that may be collected automatically includes:
Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.
Information Collected from Others. We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners or publicly available sources.
Cookies and Other Technologies. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Site and third-party websites and online services. This information, which may be used internally or for marketing purposes generally, allows us, among other things, to improve the delivery of our Site to you, analyze usage, and measure traffic on the Sites. We review our users' preferences, interests, demographics, traffic patterns, and other information so that we can better understand our audience and what they want.
How We Use Your Personal Data
To operate the Services. We may use your personal information to:
To send you marketing and promotional communications. We may send you company related marketing communications as permitted by law. You will have the ability to opt out of our marketing and promotional communications as described below.
To serve advertisements. We work with advertising partners to display advertisements on the Services. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”
To display user testimonials and feedback. We often receive testimonials and comments from users who have had positive experiences with our Products and Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting his or her name along with the testimonial. In addition, we may post user feedback on the Site from time to time. We will share your feedback with your approve name only. If you make any comments on a blog or forum associated with our Site, you should be aware that any personal data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data records from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by excluding information (such as your name) that makes the data personally identifiable to you. We may use this data and share it with third parties for our lawful business purposes.
For compliance. We may use your personal information to:
How We Share Your Personal Information
We do not share your personal information with third parties without your consent, except in the following circumstances or as described elsewhere in this Privacy Policy:
Service Providers. We may share your personal information with third-party service providers to: provide you with the Services that we offer you, including through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company. These third-party service providers are required not to use your personal information other than to provide the services requested by Company.
Affiliates. We may share some or all of your personal information with our parent company, subsidiaries, joint ventures, or other companies under a common control, in which case we will require our Affiliates to honor this Privacy Policy.
Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.
Third-Party Companies. We may enter into agreements with business partners, such as companies that aggregate consumer data to facilitate advertising. We do not share California residents’ personal information in this manner.
Advertising Partners. When we use third-party cookies and other tracking tools, our advertising partners may collect information from your device to help us analyze use of the Service, display advertisements on the Service and advertise the Service (and related content) elsewhere online.
Third-Party Platforms and Social Media Networks. If you have enabled features or functionality that connect the Service to a third-party platform or social media network, we may disclose the personal information that you authorized us to share. We do not control the third-party’s use of your personal information.
Compliance. We may share personal information with law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance purposes described above.
Third-Party Websites
Our Site may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect personal data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
Your Choices Regarding Your Information.
You have several choices regarding use of information on our Services:
Targeted Online Advertising
Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
If you choose to opt-out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
Security of Personal Information
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
For online payments and/or Automated Clearing House (ACH) payouts, we use the payment services of Braintree (https://www.braintreepayments.com/) and/or Shopify (https://www.shopify.com/). We do not process, record or maintain your credit card or bank account information. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to Braintree’s Privacy Policy (https://www.braintreepayments.com/legal/braintree-privacy-policy) and Shopify’s Privacy Policy (https://www.shopify.com/legal/privacy).
Data Retention
We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we may consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will post them on the Sites and indicate the effective date of the change. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Services.
Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Notice to California Residents
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal Information, and of the rights and choices we offer California residents regarding our handling of the personal information.
Personal Information We Collect, Use and Share
We do not sell personal information. As we explain in this Privacy Policy, we use cookies and other tracking technologies to analyze website traffic and facilitate advertising. If you would like to opt out of our (and our third-party advertising partners’) use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-out Guide below.
In addition to the information in our Privacy Policy, the following chart further describes our privacy practices with respect to the personal information of our California consumers.
|
Personal information we collect |
CCPA-defined categories |
Sources of personal information |
Purposes for which we may collect and use the personal information |
Data Sharing |
|
Account Registration Survey Data Purchases |
Identifiers Online Identifiers Commercial Information Financial Information Physical Description Protected Classification Characteristics |
You |
To operate the Services To send you marketing and promotional communications |
Shared with third-party platforms at your direction |
|
Contact Information Feedback Information You Provide to Social Media Platforms |
Identifiers Online Identifiers Education information Professional or Employment Information Physical Description Sensory Information |
You Third Parties |
To operate the Services To send you marketing and promotional communications To display user testimonials and feedback |
Shared with third-party platforms at your direction |
|
Device Data Online Activity Data |
Online Identifiers Internet or Network Information Inferences |
You Automatic collection |
To operate the Services To send you marketing and promotional communications To display advertisements |
Collected directly by advertising partners |
Please note that we may also disclose all personal information to Affiliates and service providers, or for purposes of corporate restructuring and compliance, as described in the “How We Share Your Personal Information” section of the Privacy Policy.
California Residents’ Privacy Rights
Except as excluded from the scope of this notice above, the CCPA grants California residents the following rights.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
You are entitled to exercise the rights described above free from discrimination.
How to Submit a Request. To request access to or deletion of personal information:
Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We may attempt to verify your identity by asking you to confirm the information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have written authorization confirming such authority.
|
Glossary |
|
|
Statutory Category |
Data Elements within the Category |
|
Commercial Information |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
|
Education Information |
Personal information from an educational record, which could include: a student’s name, the names of the student’s parent or other family members, the address of a student or student’s family, a student’s personal identifier (e.g., SSN, student number), other indirect identifiers of the student (e.g., date of birth, place of birth, mother’s maiden name), other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty, or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates. |
|
Financial Information |
Bank account number, debit or credit card numbers, insurance policy number, and other financial information. |
|
Identifiers |
Real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. |
|
Inferences |
The derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. |
|
Internet or Network Information |
Browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement. |
|
Online Identifiers |
An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device. |
|
Physical Description |
An individual’s physical characteristics or description (e.g., hair color, eye color, height, weight). |
|
Professional or Employment Information |
This term is not defined in the CCPA, but likely includes any information relating to a person's current, past or prospective employment or professional experience (e.g., job history, performance evaluations). |
|
Protected Classification Characteristics |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
|
Sensory Information |
Audio, electronic, visual, thermal, olfactory, or similar information. |
Online Tracking Opt-Out Guide
Like many companies online, we may use services provided by Google, Facebook and other companies that use tracking technology. These services rely on tracking technologies – such as cookies and web beacons – to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.
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