Effective Date: May 25, 2020
For the purposes of this Policy, “personal data” or “personal information” shall have the meaning given to such terms by the EU General Data Protection Regulation (“GDPR”). Brush Pallate commits to cooperate with EU data protection authorities (“DPAs”) and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) and comply with the advice given by such authorities with regard to data transferred from the EU and Switzerland.
Being transparent is important to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We will only process your personal data in accordance with applicable data protection and privacy laws, and subject to your consent. You have the ability to object to certain uses of information about you and you may access or update certain information about you. If you do not accept this Policy, you should not access or use our Services or interact with any other aspect of our business.
For the purpose of EU data protection legislation, the data controller is Brush Pallate, Inc., of 386 Park Avenue South, 6th Floor, New York, NY 10016.
Legal Basis for Processing Personal Data
Our legal basis for processing personal information is Article 6, subsection 1(f) of the GDPR, because we need to analyze website usage in order to optimize and deliver the best possible user experience.
Information We Collect
Brush Pallate obtains personal data about you when you provide such information in the course of various interactions, including:
– Visiting our website(s)
– Communicating with us via telephone or e-mail, such as contacting customer support
– Engaging with our content via social media
– Participating in events or promotions
We also may obtain personal information about you from our business partners, clients, and other third parties.
Automatically from cookies
We automatically log information about you and your computer or mobile device. For example, we log your IP address and unique cookie ID using cookies. Please refer to the sections on Cookies below.
When you visit and interact with our websites, the types of information that may be collected via a cookie includes the following:
1. your computer’s Internet Protocol (IP) address;
2. your browser type and operating system;
3. search terms that you use to reach the site;
4. the web pages you were visiting immediately before and after you came to the site;
5. dates and times of visits to the site;
6. information on actions taken on the site (such as page views and site navigation patterns);
7. amount of time spent viewing certain pages or screens;
8. standard server log information;
9. social actions taken with respect to the content on the site, including but not limited to likes and shares on LinkedIn and Facebook; and/or
10. advertisement interaction and viewing data, such as ad click-through rates and information about how many times you viewed a particular ad.
Information From Social Networking Sites
Our website includes interfaces that allow you to connect with social networking sites (each an “SNS”). If you connect to an SNS through our site, you authorize us to access, use, and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
Please note that Brush Pallate’s website(s) may contain links to other websites and gather data from social media sites, including LinkedIn, Facebook, Twitter, and Pinterest. We recommend that you read the privacy policies of the aforementioned sites and every website that you visit. We are not responsible for those sites’ privacy practices.
When you visit our website(s), Brush Pallate may also collect information about your online activities over time and across third-party websites or online services.
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site. We use two broad categories of cookies: (1) first-party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site; and (2) third-party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies we use
Our site uses the following types of cookies for the purposes set out below:
Essential Cookies: These cookies are essential to provide you with services available through our site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies: These cookies allow our us to remember choices you make when you use our site, such as remembering your language preferences, and remembering your login details. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our site.
Analytics and Performance Cookies: These cookies are used to collect information about traffic to our site. The information gathered does not identify any individual visitor. The information is aggregated and therefore anonymous. It includes the number of visitors to our site, the websites that referred them to our site, the pages that they visited on our site, what time of day they visited our site, whether they have visited our site before, and other similar information. We use this information to help operate our site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button on our site or you link your account or engage with our content on or through a social networking website
such as Facebook or LinkedIn. The social network will record that you have done this.
You can also typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
We also use tracking pixels through img tags on our website to track the visitors’ actions. Such tags are embedded within each particular page of the website. Pixel tags allow us to measure the performance of our content and gather statistics about overall website usage. Pixel tags only track IP addresses for the sole purpose of counting unique visitors.
How We Use Your Information
In order to learn more about how our websites are used, we aggregate and analyze the data that we collect. We may use this information, for example, to monitor and assess use of the website, to increase our websites’ functionality, and to better tailor our content and design to suit our visitors’ needs. Cookies help us to improve our websites and to deliver a better and more customized service. They enable us:
1. to estimate usage numbers and patterns;
2. to store information about your preferences, and to allow us to customize our respective websites according to your individual interests;
3. to measure the success of our marketing campaigns
4. to speed up your searches; and
5. to recognize you when you return to our website
Brush Pallate may use combined information to enhance and personalize your online experiences, to communicate with you about products, services and events that may be of interest to you, and for other promotional purposes. We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection. We will not share, sell, or otherwise distribute your personal data to any third parties, except as outlined herein and absolutely necessary.
You may provide your email address to us or other contact information to receive industry news, intelligence, information about Brush Pallate products and services, and other business communications. You may opt out of our email marketing communications using the link at the bottom of each email. Please note that even if you opt out, you may continue to receive certain email communications from us regarding your relationship with Brush Pallate, such as updated in our site terms.
In the event Brush Pallate goes through a business transition, such as a merger, acquisition by another company, or sale of a portion of its assets, users’ personal data will, in most instances, be part of the assets transferred.
We may share the information we maintain about you with our service providers, business partners and clients. Brush Pallate also may need to disclose personal data when required by law and/or when we have a good-faith belief that such action is necessary to comply with a) a current judicial proceeding, b) a court order or c) legal process served on Brush Pallate.
If you participate in certain features of this website (e.g., sharing content), please note that any information you voluntarily disclose through use of these features becomes available to the public and/or to other users whom you have designated.
All data is encrypted. Brush Pallate has technical, administrative and physical safeguards in place to help protect against unauthorized access to, use or disclosure of user information we maintain. We recognize, however, that no program is one hundred percent secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose personal data. If you become aware of a security issue, please email us at legal [at] Brush Pallate [dot] com. We will work with you to address any problems.
Your Rights and Choices
You may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal data, including the sharing of your information with third parties, by emailing privacy [at] Brush Pallate [dot] com. We will apply your preferences going forward. In some circumstances, withdrawing your consent to Brush Pallate’s use or disclosure of your personal data will mean that you cannot take advantage of certain Brush Pallate products or services.
You may also access the information we hold about you. If you wish to exercise this right, please contact us at privacy [at] Brush Pallate [dot] com. You can contact us to update or correct any inaccuracies in the personal data we hold about you. In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal data that you have provided to us. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
We will retain your personal data for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. You have every right to request that we delete your data altogether.
In compliance with the Privacy Shield Principles, Brush Pallate commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Brush Pallate at: [email protected] and/or 212-989-4100.
Brush Pallate has further committed to refer unresolvedPrivacyShield complaints to EU data protection authorities, an alternative dispute resolution provider located in the EU. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit the EU data protection authorities for more information or to file a complaint. The services of the EU data protection authorities are provided at no cost to you.
Brush Pallate is subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”). As such, we will be held liable for any personal data breaches or transfers. We may be required to disclose personal data in response to lawful requests by the FTC or other public authorities. You have every right to invoke binding arbitration in certain limited circumstances.
Notification of Changes