Privacy

Effective Date: October 21, 2016

Brightstar’s Global Privacy Statement

1. General

Brightstar is committed to protecting your privacy and ensuring you have a positive experience on our websites. This Privacy Statement (“Statement”) applies to Brightstar’s external websites (each individual website being a “Site”) and describes how we handle information that can be used to identify you (“Personal Information”), which may include your name, address, email address, phone number, marketing preferences, opinions, etc. This Statement informs the choices available to you regarding the use of, your access to, and ability to update and correct your Personal Information. If we link other data with your Personal Information, we will treat that linked data as Personal Information.

This Statement is applicable globally but may be supplemented by additional information on our privacy practices that may be provided as required by applicable laws and regulations via notices provided at the time of data collection. Further, certain Brightstar websites may have additional information not contained in this Statement that describes how we handle Personal Information for those websites specifically. To the extent a notice provided at the time of collection or a website-specific privacy statement conflicts with this Statement, such notice or privacy statement will control. This Statement also supplements and is incorporated into the Terms of Use for this Site.

2. Information Collected & Uses

The types of Personal Information collected and used by Brightstar depend on specific activities as described below.

  • If You Send Us an E-Mail: You may choose to provide us with Personal Information when you contact us via email or within a Site with a comment or question. In these cases, we use the Personal Information you provide to respond to your request and/or improve our service to you.
  • If You Sign Up or Participate in Site Surveys: A Site may offer you the option of adding your name and e-mail address to a distribution list for information on new products and services, special offers and other marketing opportunities. From time to time, a Site may also solicit your feedback or offer opportunities to participate in surveys and questionnaires. We use the information you provide in surveys and questionnaires to help us design and build better products, to customize your experience, and to provide advice and purchase recommendations. We will not add your name and e-mail address to such a lists or require you to participate in surveys and questionnaires unless you affirmatively, voluntarily permit us to do so. If you choose to be added to a distribution, you have the ability to remove your name and e-mail address at any time as described for that particular distribution.
  • Research Data: For certain Sites, we may conduct research on our users’ demographics, interests, and behavior based on the information provided to us from surveys, questionnaires and/or from our server log files. We do this to better understand and serve our users. This research is compiled and analyzed on an aggregated basis so as to prevent identification of personal information relating to any one individual.

3. Sharing with Third Parties

Except as outlined below, where required by applicable laws, we will not disclose your Personal Information to third parties without your consent.

We may provide information about a user who is a customer to a third party as necessary in order to process that customer’s request or order, or otherwise service a customer’s account.

We will disclose or report Personal Information in limited circumstances where we believe in good faith that disclosure is required under applicable laws, to cooperate with regulators or law enforcement authorities, respond to claims, and to protect the rights, property or safety of Brightstar or others. This may include, for example, the exchange of information with other organizations for fraud protection and credit risk reduction.

We will use your e-mail or other address (e.g., physical address) to send you important information relating to your account.

We do not share the names and e-mail addresses of recipients of our distribution lists or the results of our surveys and questionnaires with third parties, including sellers. However, we may share aggregated and anonymized research data with business partners in certain circumstances, for example, in order to collect funds owed to us by the business partner or in order to administer our relationships with those partners.

4. Retention of Personal Information

We will retain and use your Personal Information as needed to fulfill the purposes for which it was collected and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements under applicable laws.

5. Cookies

When you enter one of our Sites, our server attaches a small text file to your hard drive — a cookie. A “cookie” assigns you a unique identifier so that we can recognize you each time you re-enter our Site, allowing us to recall where you’ve previously been on our Site and help you track the pages you view on our Site. Cookies help us deliver a better Site experience to our users.

The information collected from a cookie is sometimes called “clickstream.” We use this information to understand how our users navigate our Sites, and to determine common traffic patterns, including what other external sites the user is visiting from. We may also use this information to make site navigation and product recommendations and to help redesign our Sites, better personalize content, banner ads, and promotions that you and other users will see in an effort to make your experience on our Sites more efficient and enjoyable.

You have choices with respect to information collected from the use of cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. If you choose to reject all cookies, you will be unable to access those services or activities that require the placement of cookies. Further, certain aspects of the Sites may not function properly if you set your browser to reject all cookies.

6. Security

Our Sites use Secure Sockets Layer (SSL) encryption technology. The SSL protocol provides server authentication, data integrity, and privacy on the Web. SSL encrypts your information as it is being transmitted, verifies the identity of the server and helps ensure that the original message arrives at its destination.

Although it is not possible to guarantee that data transmission over the Internet is 100% secure, we strive to protect your information to the extent possible. Once we receive your transmission, we use our best efforts to ensure its security on our systems. Further, we have incorporated industry-accepted security measures into the design, implementation, and day-to-day operations of our Sites.

However, please be aware that we cannot guarantee or warrant the security of any information you transmit to us or from our Sites. We also cannot be responsible for criminal acts of third parties, such as “hackers,” who may seek to compromise our security measures through unlawful means. Therefore, your use of our Sites is considered to be at your own risk.

7. Information About Minors

Our Sites are intended to be used by other businesses and adult customers. Brightstar does not seek to collect any Personal Information about minors. No information should be submitted to or posted on our Sites by minors.

8. Endorsements and Links to Other Sites

Our Sites may contain advertising for commercial information purposes such as hyperlinks to, or web addresses of, other businesses or organizations. When you visit such other links or web addresses, you are no longer within our Site and you become subject to the privacy and security policies of the new site. We do not review and are not responsible for these other privacy and security policies within other sites.

9. Prohibitions on Use

The following activities are strictly prohibited under this Statement:

  • Using our Sites to transmit any material (by email, instant messaging, posting or otherwise) that, intentionally or unintentionally violates any applicable local, state/provincial, national or international law, or any rules or regulations promulgated hereunder is prohibited.
  • Using our Sites to access or to attempt to access the accounts of others or to penetrate or attempt to penetrate security measures of Brightstar’s or another entities computer software or hardware, electronic communication system, or telecommunication system, whether or not the intrusion results in the corruption or loss of data is prohibited.
  • Using our Sites to collect or attempt to collect information about third parties without their knowledge or consent is prohibited.

10. Consent to Transfer, Process & Store Personal Information

As Brightstar is a global organization, we may transfer your personal information to Brightstar in the United States of America, to any Brightstar subsidiary worldwide, or to third parties and business partners as described above. By using our Site or providing any personal information to us, where applicable law permits, you consent to the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different.

11. How to Contact Us

We value your opinions and feedback. Should you have questions or comments related to this Statement or wish to access or correct Personal Information held by Brightstar about yourself, please contact Brightstar’s Global Ethics & Compliance Office at Ethics&Compliance@Brightstar.com.

12. Updates to this Statement

We may update this Statement as necessary from time to time. If we modify our Statement, we will post the revised version to our Sites with an updated revision date.

In order to be aware of and review any such revisions, you agree to visit our Sites periodically. If we make material changes to our Statement, where required by applicable laws, we may also notify you by other means prior to the changes taking effect, such as by posting a specific notice on our Sites or sending you a notification. By continuing to use our Sites after such revisions are in effect, you accept and agree to abide by the updated Statement.