1. About This Privacy Policy

This privacy policy applies when you visit or use our websites, apps and other services, including events, that refer or link to this privacy policy (each, a “Service”). This privacy policy may be supplemented by additional privacy statements, terms or notices provided to you.

The Simple Associate, Inc., dba Briefpoint company that owns or administers the Service, as identified therein, is the primary controller of your personal information provide to, or collected by or for, the Service.

We will indicate within the registration processes of our products and services and other registration forms what types of personal information are required and those that are requested. You may choose not to submit the requested information, but that may limit or prohibit the services that Briefpoint is able to provide to you.

2. Information We Collect

We collect information about you in three ways: directly from your inputs and/or uploads, from third-party sources, and through automated technologies.

2.1 Data You Provide to Us

The types of personal information that we collect directly from you depends on how you interact with us and the Service, which may include:

2.2 Data from Your Organization

We may obtain personal information about you from the organization with which you are employed or affiliated in order to activate and manage your access to and use of the organization’s subscription to the Service, including:

2.3 Data from Other Sources

We also may obtain contact details and other information about you from our affiliates and from other third parties, including:

2.4 Data From Service Use, Including Cookies

The Service may automatically collect information about how you and your device interact with the Service, including:

We collect this data through our servers and the use of cookies and other technologies. Cookies are small text files that can be read by a web server in the domain that put the cookie on your hard drive. We may use cookies and other technologies to store your preferences and settings, help you with signing in, provide targeted ads and analyze site operations. You can control cookies through your browser’s settings and other tools. However, if you block certain cookies, you may not be able to register, login, or access certain parts or make full use of the Service. For more details, see the cookie policy of the Service.

3. How We Use Your information

Depending on how you interact with us and the Service, we use your personal information to:

If you are an administrator of an organization with a subscription to the Service, we will use your details to communicate with you about your organization’s subscription and related services. If you supply us contact information of your colleagues, we may contact those individuals with communications about the Service that may include reference to you.

4. Sharing of Your Information

4.1 Your Organization

If you access the Service through a subscription administered by your organization, your personal information and certain usage data gathered through the Service may be accessed by or shared with the administrators authorized by your organization for the purposes of usage analysis, subscription management and compliance, training course progress, performance and remediation, cost attribution and departmental budgeting.

4.2 Application Licensor

If you access a third-party application on the Service through a license agreement with the licensor of that application, personal information relevant that third-party application may be shared with the licensor so that it can provide you access to the application, subject to the terms of its license agreement and privacy policy.

4.3 Our Group Companies and Service Providers

Dependent upon the Services provided, we share information with:

to process the information as necessary to provide the Service, complete a transaction or fulfill your request or otherwise on our behalf based on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures.

4.4 For Legal Reasons

We also will disclose your personal information if we have a good faith belief that such disclosure is necessary to:

5. Grounds for Processing

When we collect or otherwise process any personal information within the scope of applicable data protection laws, we do so:

Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.

6. Data Retention

We retain your personal information for as long as necessary to provide the Service and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. If you access the Service through a subscription administered or sponsored by your organization, we retain your organizational contact details after the termination of your organization’s subscription to continue to communicate with you.

7. Locations of Processing

Your personal information may be stored and processed in your region or another country where The Simple Associate, Inc., its affiliates, and their service providers maintain servers and facilities. 

8. Data Security

We implement technical and organizational measures to seek to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the integrity, confidentiality, and availability of personal information.

9. Children’s Privacy

We do not knowingly collect information from children under the age of 13 or target the Service to children under 13.

10. Your Communications Preferences

You can customize and manage your communications preferences and other settings when you register with the Service, by updating your account features and preferences, by using the “opt-out” mechanisms such as “unsubscribe” or other means provided within the communications that you receive, or by contacting us. We reserve the right to notify you of changes or updates to the Service whenever necessary.

11. Accessing and Updating Your Information

11.1 Your Account

The Service may allow registered users to directly access and review their account information and make corrections or updates upon login at any time. Keeping such information up to date is the responsibility of the user. Registered users may also close their account directly through the Service or by contacting the Service’s customer support, at support@briefpoint.ai.

11.2 Your Rights

You may have the right under applicable privacy and data protection laws to request, free of charge:

If you wish to exercise these rights, please submit your request in writing to support@briefpoint.ai. We will respond to your request consistent with applicable laws. To protect your privacy and security, we may require you to verify your identity.

12. Changes

We will update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. If we make any material changes, we will provide notice through the Service or by other means.

13. Contact

If you have any questions, comments, complaints or requests regarding this privacy policy or our processing of your information, please contact us at support@briefpoint.ai.

You may also lodge a complaint to a data protection authority in the applicable jurisdiction.

14. Supplementary Notices

14.1 California Privacy Rights

1. About this Privacy Notice

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), The Simple Associate, Inc., dba Briefpoint (“Briefpoint”) is providing this California Consumer Privacy Act Notice (“CCPA Notice”). This CCPA Notice supplements our Privacy Policy (above) and applies solely to California consumers, effective January 1, 2020. Terms used but not defined shall have the meaning ascribed to them in the CCPA. This CCPA Notice does not apply to personal information that we process as a service provider on behalf of our customers or that we collect from job applicants, contractors, or employees.

2. Personal Information Collected and Disclosed

We collected and disclosed the following categories of personal information in the preceding 12 months as indicated with a checkmark below:

	Collected	Disclosed
A. Identifiers such as a real name, alias, Bar number, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name.	✔	✔
B. Personal information as defined in the California customer records law, such as name, contact information, education, employment, employment history and financial information.	✔	✔
C. Characteristics of protected classifications under California or federal law, such as gender and date of birth.	✔	✔
D. Commercial information, such as transaction information, purchase history, financial details, and payment information.	✔	✔
E. Biometric information, such as fingerprints and voiceprints.	✘	✘
F. Internet or other electronic network activity information, such as interactions with our websites, applications, systems, and advertisements.	✔	✔
G. Geolocation data, such as device location.	✔	✔
H. Audio, electronic, visual, and similar information, such as images and audio, video or call recordings created in connection with our business activities.	✔	✔
I. Professional or employment-related information, such as job title as well as work history and experience.	✔	✔
J. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.	✘	✘
K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.	✔	✔

We collect this personal information from you and from other categories of sources such as: our affiliates; our customers; public and publicly available sources; our third-party resellers and referral partners, data suppliers and service providers; partners with which we offer co-branded services or engage in joint event or marketing activities; social networks; news outlets and related media; and the organization with which you are employed or affiliated.

We share this personal information with: our affiliates; our customers; our service providers, agents and representatives; joint venture partners; distributors, referral partners and integrators; the administrators authorized by your organization (if you access our services through a subscription administrated by your organization); licensors of third-party applications (if you access a third-party application on our services through a license agreement with the licensor); and other parties where required by law or to protect our rights.

We may use this personal information to: operate, manage, and maintain our business, to provide our products and services, to communicate with you, for our vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using personal information to: develop, improve, repair, and maintain our products and services; process or fulfill a request or other transactions submitted to us; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions; comply with law, legal process, and internal policies; maintain records; exercise and defend legal claims; and fulfill legal obligations.

We disclose the above categories of personal information to: our affiliates; our customers; our service providers, agents and representatives; joint venture partners; distributors, referral partners and integrators; the administrators authorized by your organization (if you access our services through a subscription administrated by your organization); licensors of third-party applications (if you access a third-party application on our services through a license agreement with the licensor); and other parties where required by law or to protect our rights.

The Simple Associate, Inc. does not sell personal information to third parties within the scope of the application of the CCPA.

3. Consumer Rights

You have the right to request that we disclose to you (i) the categories of personal information we collected about you and the categories of sources from which we collected such information; (ii) the specific pieces of personal information we collected about you; (iii) the business or commercial purpose for collecting personal information about you; and (iv) the categories of personal information about you that we shared or disclosed for a business purpose and the categories of third parties with whom we shared or to whom we disclosed such information in the preceding 12 months.

You also have the right to request that we delete personal information we collected from you subject to certain exceptions.

You also have the right to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA. Briefpoint does not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information.

4. How to Make a Request

You may make a request for the disclosures or deletion described above by emailing support@briefpoint.ai.

You may be required to submit proof of your identity for these requests to be processed as a verifiable consumer request. Such information may include your name, home address, social security number or driver’s license. This information will be used only for the purposes of verifying your identity and processing your request. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization. Requests made through an authorized agent should be made to support@briefpoint.ai.

We will respond to your request consistent with the CCPA, which does not apply to certain information, such as information made available from government records, certain data subject to the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA) and certain other laws, and where its application is preempted by, or in conflict with, federal law or the United States or California Constitution.

5. Changes

We will update this CCPA Notice from time to time. Any changes will be posted on this page with an updated revision date.