Springbrook Holding Company, LLC
Privacy Policy

Introduction

This Privacy Policy was updated on or about May 1, 2023.

Springbrook Holding Company, LLC and its affiliated companies and subsidiaries (collectively referred to as “Springbrook,” “we,” or “us”) respect your privacy. This Privacy Policy describes how we collect Information from and about you, what we do with the Information, how we share it, and how we handle the content you place in our products and services. It also explains the choices available to you regarding use of your Personal Information. By providing Information or Personal Information to us including on our website or purchasing our products or services, or signing an agreement that incorporates this Privacy Policy by reference you agree to this Privacy Policy.

Scope of this Privacy Policy

This Privacy Policy applies to the Information we obtain through your use of Springbrook’s products and services or visitation to Springbrook websites where this Privacy Policy is posted. It does not apply to any other Information collected by Springbrook through other means. If you have agreements with Springbrook for Springbrook products and services, then those agreements control to the extent of any conflict. Further, this Privacy Policy does not cover the activities of third parties except as specifically stated.

Definitions

Downloadable Products means Springbrook’s downloadable software products and mobile applications, including bundles of code, resources, and configuration files that can be used with a Springbrook product to add new functionality (including product version upgrades) created by Springbrook that are installed by customers on a device of their choice.

Information means all forms of data, content (which includes data that you upload, submit, post, create, transmit, store or display in a Springbrook product or service), and information collected by us.

Personal Information means Information that may be used to readily identify or contact you as an individual person, such as: name, address, email address or phone number. Personal Information does not include Information that has been anonymized such that it does not allow for the ready identification of specific individuals.

Our Collection of Personal Information

Springbrook collects Personal Information from you at several different points, including but not limited to the following: when we correspond with you as a customer or prospective customer; when you use our products or services; when you visit, register, or otherwise provide us your Personal Information on our website; when you contact us for help; when you interact with our advertising and marketing content; and when you participate at our conferences, attend our webinars, or visit our tradeshow booths.

In using our products or services or requesting Information, you may provide a password for your account, your real name, industry, agency name, job role and contact Information. We may also collect other information including but not limited to the specific Springbrook product or service being used, the associated license identifier and domain name, financial information (for example, information about your payment card numbers), the username and IP address or the individual using the product or service function; your credit card number and billing address when purchasing an Springbrook product or service; analytics Information including aggregated usage data; and other additional Information required to detail the operation of the Springbrook product or service.

Our Use of your Information and Personal Information

Springbrook may use your Information and Personal Information to:

Our Disclosure of your Personal Information to Third Parties

We may share your Personal Information with third parties only in the ways that are described in this Privacy Policy:

Our Security Measures to Protect your Personal Information

We have put in place reasonable and appropriate physical, electronic, and managerial procedures in an effort to help safeguard Personal Information we collect. However, Springbrook cannot fully eliminate security risks associated with Personal Information. To help protect yourself, please use a strong password, do not use the same passwords you use with other accounts or services, and protect your usernames and passwords.

End Customer Data

Springbrook’s customers may electronically submit Information to the product or service for processing and storage purposes (“End Customer Data”). We may access or process End Customer Data only for the purpose of providing a product or service or preventing or addressing service or technical problems or as may be required by law. If your Personal Information has been submitted to us by a Springbrook customer and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with the relevant customer directly. Since Springbrook personnel have limited ability to access Information our customers submit to our products or services, if you wish to make your request directly to Springbrook, please provide the name of the Springbrook customer who submitted your data to our product or service. We will refer your request to that customer.

Our Retention of your Personal Information

Personal Information will be retained as long as needed to fulfill legitimate business purposes for which it was collected, including the purposes outlined in this Privacy Policy, or for a period of time specifically required or allowed by applicable regulations or laws. We will also retain and use your Personal Information for as long as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Cookies/Web Beacons

Our websites use cookies to recognize you when you visit our website. We use cookies and similar tracking technologies to collect information on our website, mobile application, and via email.

Cookies are small text files that are stored on your computer. They are designed to hold a small amount of data specific to a website or server that can be accessed either by the website or your computer. We use cookies to capture information such as IP address and electronic activity data.

We use this information to remember your site preferences. Additionally, we aggregate this data to analyze site traffic and the effectiveness of our marketing efforts.

When you use our websites, you can usually choose to set your browser to remove cookies and to reject cookies from our servers. If you choose to remove or reject cookies, this could affect certain features or services of our websites.

While we and others give you certain choices, as further outlined in this Privacy Policy, there are many ways that web browser signals and similar mechanisms can indicate your choice to disable tracking, and we may not be aware of nor honor every mechanism.

Do Not Track

Most modern web browsers give you the option to send a Do Not Track signal to the sites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a site should respond to this signal, and we do not take any action in response to this signal. Instead, in addition to publicly available third-party tools, we offer you the choices described in this policy to manage the collection and use of information about you.

International Storage and Transfer of your Personal Information

Springbrook is a global company with affiliates, various business processes, management structures and technical systems that cross borders. Information collected by Springbrook or on behalf of Springbrook may be stored on our computers, on our mobile devises, or on our servers, and may be transferred to, accessed from, or stored and processed in the United States.

Your Access to and Amendment of your Personal Information

Our marketing emails tell you how to “opt-out” of receiving further marketing emails. If you opt out, we may still send you non-marketing emails including emails about your accounts and our business dealings with you.

We allow you to access your Personal Information (with proper identification verification), and allow you to correct, amend or delete inaccurate Personal Information, except where the burden or expense of providing such an access is disproportionate to the individual privacy risk, or where the rights of persons other than the requesting individual risk being violated. This information request can be made by sending an email to [email protected].

Children’s Privacy

Because of the nature of our business, our services are not designed to appeal to minors. We do not knowingly attempt to solicit or receive any information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us immediately.

For California Residents

This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

For the purposes of the CCPA, “Personal Data” means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

Personal information does not include:

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

Please note that the examples provided above are illustrative and not intended to be exhaustive. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration.

We do NOT sell any information to any parties.

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

If you have reason to believe that a child under the age of 16 has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

Exercising your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact Us:

Only You, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.

Your request to us must:

We cannot respond to your request or provide you with the required information if we cannot:

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

Changes to This Privacy Policy

From time to time, we may collect and use Personal Information in ways not previously disclosed in our Privacy Policy. If our information practices or this policy change, we will post adjustments to this policy and change the “Last Updated” date. Unless additional notice or consent is required by applicable laws, this will serve as your notification of these changes.

Contacting Us

If you have questions or suggestions, please email Springbrook at [email protected]. Please send all written communication to:

Springbrook Holding Company, LLC
Attn: Legal Department
21370 SW Langer Farms Pkwy STE 142-507
Sherwood, OR 97140