© Copyright 2022 Brahms, Inc. — All rights reserved.
© Copyright 2022 Brahms, Inc. — All rights reserved.
Brahms LLC
Overall Privacy Policy
Last Revised: August 8, 2022
Brahms LLC (“Brahms,” “we,” “us,” and “our”) strives to protect the privacy of its users, store owners, and customers. This privacy policy (the “Policy”) will help guide your use of the Services (defined below) and inform you of what Brahms may or may not do with certain data and information.
We know that your privacy is important to you, and we work hard to earn and keep your trust. We respect your privacy and are committed to protecting your privacy through our compliance with this Policy. We may collect and use information about you, including you as a:
This Policy and the privacy policies linked above describe:
This Policy applies to information we collect on the Platform or in emails and other electronic messages between you and the Platform, and information gathered when you interact with our advertising, if any, on third-party websites if such advertisements include links to this Policy.
This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Platform (for further information, see below, “Third-party Websites”).
Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Platform. By using our Platform, you agree to the terms of this Policy. Brahms reserves the right to change this Policy from time to time (see below, “Changes to this Policy”). Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
This Policy should be read in conjunction with any applicable Terms of Service or other agreements, which may include the following:
To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). For more information on what Personal Information we collect from Merchants, Vendors, Shoppers, and Visitors, please see the privacy policies for each type of user.
The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting Brahms to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal information, unless required for our services.
Additionally, we may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous. Moreover, we may receive information about you from other sources and add it to the information you have provided to us.
In addition to the information that you provide to us, we may also collect information about you during your visit to our Platform. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Platform. Some of the tools we use to automatically collect information about you may include:
(a) Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:
(1) session cookies, which do not stay on your device after you close your browser, and
(2) persistent cookies, which remain on your device until you delete them or they expire.
We may use the following categories of cookies on our Platform.
i. Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Platform and use its features. Without these cookies, services you have requested, such as maintaining a record of your purchased items, cannot be provided.
ii. Performance Cookies. These cookies collect anonymous information on how you use our Platform to help us understand how you arrive at our Platform, browse or use our Platform and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
iii. Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Platform, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Platform more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.
iv. Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. These cookies remember the websites you visit and that information is shared with other parties, such as advertisers.
Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Platform’s features or lose access to some functionality.
(b) Google Analytics. The Platform sends aggregated non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Platform’s performance. For more information on how Google Analytics supports the Platform and uses information sent from the Platform, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.
(c) Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Platform. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.
(d) Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
(e) Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Platform and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.
The information we gather and that you provide is collected for various purposes, including, but not limited to:
Duration. The length of time Brahms intends to retain Personal Information, including sensitive information, is for as long as reasonably necessary to carry out Brahms’s intended business purpose for such information.
We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information to a third party for a business purpose. We do not control how these services may use your data or information and you should consult their terms of service and privacy policy independently.
We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.
If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.
We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.
You may have the opportunity to receive SMS or "text" messages, pre-recorded voice messages or auto-dialed phone calls from Brahms, its affiliates and related entities as well as third parties. Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested. In providing your mobile device number or cell phone number to Brahms, you knowingly consent to such communications from Brahms or for Brahms to use your cell phone number or mobile device number in accordance with Brahms’s Overall Terms of Service. In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to Brahms, or from which you sent the text message request to us. You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications to you.
Any such communications you receive from us will be administered in accordance with your preferences and this Policy.
We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and during processing.
Where we can provide you access to your Personal Information in our possession, we will ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.
To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.
We do not intentionally seek to gather information from individuals under the age of sixteen (16). We do not target the Platform to minors, and would not expect them to be engaging with our Platform or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.
We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, ideas, materials, comments or other information you provide to us (collectively, “Submissions”) will be treated as non-proprietary and non-confidential. Your Submissions on or through the Platform may be available to others who visit the Platform or a merchant store. In addition, we may use your Submissions in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Submissions for such purposes. Therefore, you should have no expectation of privacy with respect to your Submissions on or through the Platform. You should not submit any content you do not wish to make available to the general public, and you must take special care to make sure your Submissions comply with our Overall Terms of Service or other applicable agreements. All terms and conditions of our Overall Terms of Service apply to Submissions on or through the Platform. In particular, your Submissions must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Submission.
This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Platform may link to third-party websites and services. For example, if you click on an advertisement on the Platform, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.
California
Your Consumer Rights
If you are a California, Colorado, or Virginia consumer, as defined by the California Consumer Privacy Act of 2018 (the “CCPA”), the Colorado Privacy Act (“CPA”) or the Virginia Consumer Data Protection Act (“VCDPA”), respectively, you may be afforded additional rights with respect to your “Personal Information” or “Personal Data” as those terms are explicitly defined under the CCPA, CPA, and VCDPA. Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. You may exercise each of your rights as identified below, subject to our verification of your identity.
A. Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
B. Correction. You can correct what Personal Information our Platform database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any Personal Information that you have provided to us.
C. Prohibit Data Sharing. When applicable, you may prohibit the sharing of your Personal Information. In your request, please explain how you wish us to prohibit the sharing of your Personal Information, and which categories of third parties you want to prohibit from receiving your Personal Information. When such prohibitions are not possible to provide our services to you, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.
D. Portability. Upon request and when possible, we can provide you with copies of your Personal Information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy
E. Deletion. You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties.
F. Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.
G. Non-Discrimination. If a California, Colorado, or Virginia data subject exercises his or her rights under applicable state law, including the CCPA, CPA, and VCDPA, we shall not discriminate against that resident by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
H. Exercising your rights. If you are a California, Colorado, or Virginia resident who chooses to exercise the rights listed above, you can:
1. Submit a request via email at support@brahms.ai; or
2. Call us at +1 832-793-9146.
Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.
Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
Different jurisdictions have varying and sometimes conflicting data privacy laws, and we do not warrant or represent that this Policy or the Platform’s use of your Personal Information complies with the laws of every jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.
We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.
This Policy describes our current policies and practices with regard to the information we collect through the Platform. We are continually improving and adding to the features and functionality of the Platform along with the products and services we offer through the Platform. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).
We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us at:
Brahms LLC
151 Calle de San Francisco, Suite 200
San Juan, PR 00901
support@brahms.ai
© Copyright 2022 Brahms, Inc. — All rights reserved.
© Copyright 2022 Brahms, Inc. — All rights reserved.