Bramble

Privacy Policy:

This Privacy Policy describes how Bramble collects, uses and discloses information, and what choices you have with respect to the information.

When we refer to “Bramble”, we mean the Bramble entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.

Table of Contents:

  • Applicability of this Privacy Policy
  • Information We Collect and Receive
  • How We Use Information
  • Data Retention
  • How We Share and Disclose Information
  • Security
  • Age Limitations
  • Changes to this Privacy Policy
  • International Data Transfers
  • Data Protection Officer
  • Identifying the Data Controller and Processor
  • Your Rights
  • California Privacy Rights
  • Data Protection Authority
  • Contacting Bramble

Applicability of this Privacy Policy

This Privacy Policy applies to Bramble’s online workplace productivity tools and platform, including the associated Bramble mobile and desktop applications (collectively, the “Services"), Brmbl.io and other Bramble websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Bramble. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Bramble’s business.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Bramble platform (“Third Party Services”), or any other third party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of any data, files or other content submitted through Services accounts (collectively, “Customer Data”). The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls its instance of the Services (its “Workspace”) and any associated Customer Data. If you have any questions about specific Workspace settings and privacy practices, please contact the Customer whose Workspace you use. If you have an account, you can check <YOUR DOMAIN>.brmbl.io/admin/users for contact information of your Workspace owner(s) and administrator(s). If you have received an invitation to join a Workspace but have not yet created an account, you should request assistance from the Customer that sent the invitation.

Information We Collect And Receive

Bramble may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

  • Customer Data. Customers or individuals granted access to a Workspace by a Customer (“Authorized Users”) routinely submit Customer Data to Bramble when using the Services.

  • Other Information. Bramble also collects, generates and/or receives Other Information:

    1. Workspace and Account Information. To create or update a Workspace account, you or your Customer (e.g., your employer) supply Bramble with an email address, phone number, password, domain and/or similar account details. For details on Workspace creation, click here. In addition, Customers that purchase a paid version of the Services provide Bramble (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
    1. Usage Information.
    • Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, Bramble logs the times and frequency an Authorized User interacts with the workspace in order to better understand how Bramble users interact with the platform.
    • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
    • Device information. Bramble collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
    • Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Bramble may also collect location information from devices in accordance with the consent process provided by your device.
    1. Cookie Information. Bramble uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information. For more details about how we use these technologies, and your opt-out opportunities and other options, please see our Cookie Policy.
    1. Third Party Services. A Customer can choose to permit or restrict Third Party Services for its Workspace. Typically, Third Party Services are software that integrate with our Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its Workspace. Bramble may also develop and offer Bramble applications that connect the Services with a Third Party Service. Once enabled, the provider of a Third Party Service may share certain information with Bramble. For example, if a cloud storage application is enabled to permit files to be imported to a Workspace, we may receive the user name and email address of Authorized Users, along with additional information that the application has elected to make available to Bramble to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to Bramble. When a Third Party Service is enabled, Bramble is authorized to connect and access Other Information made available to Bramble in accordance with our agreement with the Third Party Provider and any permission(s) granted by Customer (including, by its Authorized User(s)). We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services. For more information on Third Party Services, click here.
    1. Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
    1. Third Party Data. Bramble may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
    1. Additional Information Provided to Bramble. We also receive Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in a certification program or other educational program hosted by Bramble or a vendor, request support, interact with our social media accounts or otherwise communicate with Bramble.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Workspace setup details, is not provided, we may be unable to provide the Services.

How We Use Information

Customer Data will be used by Bramble in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Bramble is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Workspace, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

Bramble uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Bramble uses Other Information:

  • To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.
  • As required by applicable law, legal process or regulation.
  • To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
  • To develop and provide search, learning and productivity tools and additional features. Bramble tries to make the Services as useful as possible for specific Workspaces and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, reports or expertise to an Authorized User, make Services or Third Party Service suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience, or create new productivity features and products.
  • To send emails and other communications. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Bramble. If you have additional questions about a message you have received from Bramble please reach out through the contact mechanisms described below.
  • For billing, account management and other administrative matters. Bramble may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments.
  • To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, Bramble may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

Data Retention

Bramble will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Depending on the Services plan, Customer may be able to customize its retention settings and apply those customized settings at the Workspace level, channel level or other level. Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information. For more detail, please contact Customer. Bramble may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Bramble to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

How We Share And Disclose Information

This section describes how Bramble may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Bramble does not control how they or any other third parties choose to share or disclose Information.

  • Customer’s Instructions. Bramble will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
  • Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or connected Workspaces. For example, an Authorized User’s email address may be displayed with their Workspace profile.
  • Customer Access. Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of Workspace activity, or accessing or modifying your profile details.
  • Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with Third Party Service providers to support our common customers.
  • Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. We require each Third Party Service to disclose all permissions for information access in the Services, but we do not guarantee that they do so. When enabled, Bramble may share Other Information with Third Party Services. Third Party Services are not owned or controlled by Bramble and third parties that have been granted access to Other Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third Party Services or contact the provider for any questions.
  • Corporate Affiliates. Bramble may share Other Information with its corporate affiliates, parents and/or subsidiaries.
  • During a Change to Bramble’s Business. If Bramble engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Bramble’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
  • Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective Bramble customer the average amount of time spent within a typical Workspace.
  • To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process. Please see the Data Request Policy to understand how Bramble responds to requests to disclose data from government agencies and other sources.
  • To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Bramble or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
  • With Consent. Bramble may share Other Information with third parties when we have consent to do so.

Security

Bramble takes security of data very seriously. Bramble works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Bramble has received internationally recognized security certifications. To learn more about current practices and policies regarding security and confidentiality of the Services, please see our Security Practices. Given the nature of communications and information processing technology, Bramble cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.

Age Limitations

To the extent prohibited by applicable law, Bramble does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes To This Privacy Policy

Bramble may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Bramble will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

International Data Transfers

Bramble may transfer your Personal Data to countries other than the one in which you live. We deploy the following safeguards if Bramble transfers Personal Data from jurisdictions with differing data protection laws:

  • European Union Model Clauses. Bramble offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union and the United Kingdom, and other international transfers of Customer Data. A copy of our standard data processing addendum, incorporating Model Clauses, is available here.
  • Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System And Privacy Recognition For Processors. Bramble’s privacy practices, described in this Privacy Policy, comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules (“CBPR”) system and the Privacy Recognition for Processors (“PRP”). The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies and the PRP demonstrates an organization’s ability to provide effective implementation of a personal information controller’s privacy obligations related to the processing of personal information. More information about the APEC framework can be found here.

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, Bramble is the processor of Customer Data and the controller of Other Information. Different Bramble entities provide the Services in different parts of the world.

Your Rights

Individuals located in certain countries, including the European Economic Area and the United Kingdom, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact the Customer who controls your workspace for additional access and assistance. Please check <YOUR DOMAIN>.brmbl.io/owner/account/edit for Customer contact information.

To the extent that Bramble’s processing of your Personal Data is subject to the General Data Protection Regulation (or applicable laws covering the processing of Personal Data in the United Kingdom), Bramble relies on its legitimate interests, described above, to process your data. Bramble may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Bramble’s use of your Personal Data for this purpose at any time.

Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the Information We Collect And Receive section above. We collect this information for the business and commercial purposes described in the How We Use Information section above. We share this information with the categories of third parties described in the How We Share and Disclose Information section above. Bramble does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes as further described in our Cookie Policy.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at inquiries@brmbl.io. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Bramble’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority.

If you are a resident of the United Kingdom and believe we maintain your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.

Contacting Bramble

Request a copy of your information: You may request a copy of the personal information that Bramble has about you.

Update your Information: If you already have an account, you may access, update, or alter your user profile information by logging into your account and updating profile settings.

To delete your Account: Contact an administrator in your organization.

Please note that due to the open source nature of our Services, we may retain limited personal information indefinitely in order to provide a transactional history.

California Privacy Rights

Under the California Consumer Privacy Act (“CCPA”) you are entitled to certain rights such as access to your specific personal information, details about our processing of your personal information, and the right to delete your information. You may exercise all of these rights as described in the “Your Rights and Choices” section. Bramble does not sell your personal information, as defined under CCPA, and has not done so for the past 12 months.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us. To provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by using one of the methods set forth here.

Information Bramble Does Not Collect

Bramble does not intentionally collect sensitive personal information, such as social security numbers, genetic data, health information, or religious information. Although Bramble does not request or intentionally collect any sensitive personal information, we realize that users might store this kind of information in a Bramble repository. If you are a child under the age of 13, you may not have an account. Bramble does not knowingly collect information from, or direct any of our Services to, children under 13. If we learn or have reason to suspect that a user is under the age of 13, we will close the child’s account.

Policy Changes

Bramble may change its Privacy Policy from time to time. When we do, we will update the date at the top of this Policy. If we decide to make a significant change to our Privacy Policy, we will post a notice of the update on the homepage of our Website. We may also provide notification via email of any material changes to our Privacy Policy.

Contact Us

Your information is controlled by Bramble Group Corp. If you have questions or concerns about the way we are handling your information, please email us with the subject line “Privacy Concern” at inquiries@brmbl.io.