LAST UPDATED: April 28, 2020
· Information We May Collect
· How We May Use Your Information
· How Your Information May Be Shared
· International Data Transfers
· Other Important Notices Regarding Our Privacy Practices
· User Rights
· Region-Specific Disclosures
· Privacy Shield Notice
· How to Contact Us
Information We May Collect. We may collect information from or about you, such as:
· Personal information that you voluntarily provide, including name, title, company, address, and email address.
· Login credentials.
· Communication preferences.
· Unique IDs such as IP address and device IDs.
· App-viewing activity, such as pages visited, videos watched, duration of sessions and search terms.
· Referring domain, destination domain and destination path.
· Geolocation data.
To the extent permitted by applicable law, we may also combine information you provide to us, either via our website, the App or via another means (such as at a trade show or from our customer and prospect profiles) with publicly-available information, such as your organization’s name.
Information Collected by Automated Means. We may collect certain information about you by automated means, such as your MAC address, IP address, computer or device type, screen resolution, OS version, and browser type and version. This information is collected by most websites and Apps and is used to optimize your experience with the App.
We may also use web beacons in our App and in email communications. Web beacons, also known as clear GIFs or single-pixel GIFs, are small image files that we, or our third-party service providers, place in our App and in emails. Alongside cookies, web beacons allow us to accurately count the number of unique users who have visited a specific page in the App, or opened or acted upon an email. This information allows us to measure the performance of our App and our email campaigns.
Do Not Track. The App does not recognize a “do not track” setting (or similar mechanism) from your browser to indicate that you do not wish to be tracked or to receive interest-based ads. Please see our Cookies Policy for more information including how to exercise your rights to opt-out of cookies, analytics, and personalized advertising.
How We May Use Your Information. To the extent permitted by applicable law, we may use the information collected about you for the following purposes or in the following ways:
· To communicate with you and to inform you of products, programs and services.
· To fulfill your requests and respond to your inquiries, such as to send a requested white paper.
· To send you important information regarding the App, including changes to App terms, conditions and policies. This information is important, so you may not opt out of receiving it.
· For our internal business purposes, such as for data analysis (including through automated systems and machine learning), benchmarking, reporting, audits, developing new products, enhancing our App, improving Brightcove Services, identifying usage trends and determining the effectiveness of our promotional campaigns.
· To protect the security and integrity of our App, and to prevent and to investigate fraud and other misuses.
· In an aggregated manner.
· In combination with other information, collected online and offline, including information from third-party sources, to help us update, expand and analyze our records, identify prospective customers and provide products and services that may be of interest to you.
· To comply with applicable legal or regulatory requirements and our policies, and to protect against criminal activity, claims and other liabilities.
· In any other ways, with your consent or as permitted under applicable law.
How Your Information May Be Shared. To the extent permitted by applicable law, we may share personal information as follows:
· With any of our current and future corporate subsidiaries and affiliates.
· With our third-party service providers, agents, vendors and other third parties we use to support the App and our business. These parties include, but are not limited to, third parties providing us with services such as website hosting, data analysis, infrastructure provision, IT services, customer service, analytics and email delivery services. These third parties are authorized to use your personal information only as necessary to provide these services to us.
· With third parties (including third-party event sponsors) to allow them to contact you regarding products, programs, services and promotions that they believe may be of interest to you.
· With third parties for marketing, advertising, Promotions, contests or other similar purposes. If required by applicable law, we will share such data for advertising and marketing purposes only in an aggregate de-identified manner.
· With third-party sponsors of Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to such Promotion. You should carefully review the rules, if any, of each Promotion in which you participate, because they may contain additional important information about a sponsor’s own information collection practices.
· In connection with a corporate transaction, proceeding or reorganization involving the business activities for which the information is maintained. In the event that ownership of Brightcove or its business were to change as a result of a merger, acquisition or transfer to another company, your personal information may be shared. You will be notified via email and/or a prominent notice on our App, of any change in ownership, change in use of your personal information, and choices you may have regarding such change in use of your personal information.
· As we believe necessary: under applicable law, including laws outside your country of residence; to comply with any law or directive, judicial or administrative order, legal process or investigation, warrant, subpoena, law enforcement or national security investigation or as otherwise required or authorized by law; to respond to requests from public and government authorities, including outside your country of residence; to enforce our policies, terms and conditions; to protect our operations or those of any of our affiliates; to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and to permit us to pursue available remedies or limit the damages that we may sustain.
Forums. We may enable you to post information to certain parts of the App (collectively, the “Forums”). Please note that any information you disclose through any Forum will be publicly available. We urge you to exercise discretion and caution when deciding to disclose personal information, or any other information, via any Forum. We are not responsible for the use of any personal information you disclose through any Forum. To request removal of your personal information from a Forum, contact us at firstname.lastname@example.org. We will let you know if we are not able to remove your personal information.
Cross-Device Tracking. When you use your mobile device to interact with the App, we may receive information about your mobile device, including a unique identifier for your device. We and our service providers and third parties we collaborate with, including ad networks, may use cross-device/cross-context tracking. For example, you might use multiple browsers on a single device, or use various devices (such as desktops, smartphones and tablets), which can result in your having multiple accounts or profiles across these various contexts and devices. Cross-device/cross-context technology may be used to connect these various accounts or profiles and the corresponding data from the different contexts and devices.
European Residents: If you are a resident of the European Union (the “EU”), the European Economic Area or Switzerland, please see our Additional Privacy Notice and our Privacy Shield Notice below.
Other Important Notices Regarding Our Privacy Practices.
Opt-Out. If you no longer wish to receive marketing-related emails from us, or you prefer that we not share personal information about you in the future with our affiliates and/or with third parties, you may opt out by following the “unsubscribe” instructions in the latest such message you have received or by contacting us at email@example.com. Please specify whether you are opting out of receiving messages from us or from us sharing your information with our affiliates and third parties.
We will endeavor to comply with your request as soon as reasonably practicable. If you opt out as described above, we will not be able to remove your personal information from the databases of third parties with whom your personal information has already been shared. If you wish to cease receiving marketing-related emails from such third parties, please contact them directly.
Use of the App by Children. The App is not directed to children under the age of 16. Children under the age of 16 should not provide personal information through the App. If you become aware that a child has provided us with personal information, please contact us at firstname.lastname@example.org.
You may request, and we will provide you with, information about whether we hold any of your personal information. You may request access to, or correction or deletion of your personal information, by contacting us at email@example.com. We will respond to your request within a reasonable timeframe.
Notice for Certain European Residents.
The following additional notice applies to residents of the European Union, the European Economic Area and Switzerland who visit the App.
Personal Data and Processing. For the purposes of this additional notice:
“Personal Data” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person.
“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Our lawful bases for the Processing of Personal Data are: (i) consent and/or (ii) any other applicable lawful bases, such as our legitimate interest in engaging in commerce, offering products and services of value to the users of the App, preventing fraud, ensuring information and network security, direct marketing and complying with industry practices.
Compelled Disclosures. Brightcove may be required to disclose Personal Data in response to lawful requests by public authorities, including disclosures necessary to meet national security or law enforcement requirements, or pursuant to judicial orders.
Additional Rights for European Residents. As a resident of the EU or a country following substantially-similar legislation regarding the protection of Personal Data, you may have one or more of the following additional rights available to you:
Access. To request a copy of the Personal Data we have collected about you by contacting us at firstname.lastname@example.org.
Rectification & Erasure. To request that we correct or delete any Personal Data about you that is incomplete, incorrect, unnecessary or outdated.
Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes.
Restriction of Processing. To request restriction of Processing of Personal Data about you for certain reasons, such as, if you consider Personal Data about you collected by us to be inaccurate or if you have objected to the Processing in accordance with your rights under Data Protection Laws and Regulations.
Data Portability. To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.
Right to Withdraw Consent. If Personal Data about you is Processed solely based on your consent and not for any other lawful basis, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including Processing related to existing contracts for Brightcove Services.
Right to Lodge a Complaint with a DPA. If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority (“DPA”).
To exercise any of the above-listed rights (with the exception of the right to lodge a complaint with a DPA, which you may do directly to a DPA), please contact us at email@example.com. We will process any requests in accordance with applicable law and within a reasonable period of time. We may need to verify your identity before processing your request.
Notice for Canadian Residents.
Canadian residents may have additional rights under Canadian law. Please see the information provided by the Office of the Privacy Commissioner of Canada for additional details.
Notice for California Residents
California Privacy Notice (the “CA Privacy Notice”) supplements the information
residents of the State of California (“consumers” or “you”). This CA Privacy Notice
provides additional information about how we collect, use, disclose and
otherwise process personal information of individual residents of the State of
California, either online or offline, within the scope of the California
Consumer Privacy Act of 2018 (“CCPA”).
Personal Information Disclosures
When we use the term “personal information” in this CA Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Collection and Use of Personal Information
Disclosure of Personal Information
We do not “sell” personal information as most people would typically understand that term. However, we do allow certain third-party partners and providers to collect information about consumers directly through our Site for purposes of analyzing and optimizing our Site and ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see our Cookies Policy for more information including how to exercise your rights to opt-out of cookies, analytics and personalized advertising.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
Right to Know. You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you as well as information about how we collect, use, disclose, and “sell” personal information.
Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales. You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
The Right to Non-Discrimination. You have the right not to receive discriminatory treatment for exercising any of the rights described above.
However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.
How to Exercise Your California Privacy Rights
To Exercise Your Right to Know or Right to Deletion
To exercise your right to know and/or right to deletion, please submit a request by:
We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems and/or by other means. Certain requests may require us to obtain additional personal information from you.
To Exercise Your Right to Opt Out of Personal Information Sales
We allow certain third-party partners and providers to collect information about consumers directly through our App for purposes of analyzing and optimizing our App and any ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please click this link:
which will take you to our Cookies Policy where you can exercise your rights to opt-out of cookies, analytics and personalized advertising.
If you have any questions or requests in connection with this CA Privacy Notice or other privacy-related matters, please send an email to firstname.lastname@example.org.
Alternatively, inquiries may be addressed to:
Attn: Privacy Team
290 Congress Street
Boston, MA 02210
EU-U.S. and Swiss-U.S. Privacy Shield Notice. We have certified our compliance with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield (collectively, the “Privacy Shield Framework”) with respect to the Personal Data of users of the App who are residents of the European Union (“EU”), European Economic Area (“EEA”) and Switzerland that we receive and process through the App. We certify that we adhere to the Privacy Shield Framework principles of notice, choice, onward transfer, security, data integrity, access and enforcement (the “Privacy Shield Principles”) for Personal Data of users of the App in the countries participating in the Privacy Shield Framework. Our certification is available here. We may also process Personal Data relating to individuals in Europe via other compliance mechanisms, including use of the European Union Standard Contractual Clauses.
Questions and Complaints. If you are a resident of a country participating in the Privacy Shield Framework, you may direct any questions or complaints concerning our Privacy Shield compliance to our Privacy Shield and Data Protection Contact listed below. We will work with you to resolve your issue.
If you have not received timely response to your concern relating to data processed under the Privacy Shield Framework, or we have not addressed your concern satisfactorily, you may contact our U.S.-based dispute resolution provider, at no cost to you, at https://feedback-form.truste.com/watchdog/request. If neither Brightcove nor our independent dispute resolution provider resolves your complaint, you may have the right to invoke binding arbitration through the Privacy Shield panel. However, prior to initiating such arbitration, a resident of a country participating in the Privacy Shield Framework must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from our designated independent dispute resolution provider; and (3) contact the U.S. Department of Commerce (either directly or through a European DPA) and afford the Department of Commerce time to attempt to resolve the issue. If a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Pursuant to the Privacy Shield Framework, the arbitrator(s) may impose only individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.
U.S. Federal Trade Commission Enforcement. Brightcove’s commitments under the Privacy Shield Framework are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
Privacy Shield and Data Protection Contact. Your Privacy Shield and Data Protection Contact for the personal data that we process in connection with the App is:
Attn: Chief Privacy Officer
290 Congress Street
Boston, MA 02210
Phone: +1 617 500 4947
Please include sufficient information so we can understand and respond to your specific question.
The security of personal information that Brightcove collects from App users is of great importance to Brightcove. We use organizational, technical, and administrative measures to protect personal information under our control. No data transmission over the Internet or data storage system, however, can be guaranteed to be 100% secure. When you submit personal information via a lead form in the App (such as name, phone number, and email address), we encrypt the transmission of that data. If you have any questions about the security of your personal information, you can contact us at email@example.com.
How to Contact Us.
Attn: Privacy Team
290 Congress Street
Boston, MA 02210
Please be sure to include sufficient information so we can understand and respond to your specific question or request.