1. Definitions and Interpretation In this Policy the following terms shall have the following meanings: “Account” means an account required to access and/or use certain areas and features of Our Site; “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;] “Our Site” means this website,Broadrch.com “United States and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; “We/Us/Our” means BroadReach Communications Inc a business registered in the State of Minnesota whose registered at 441 Lake Avenue, St Paul, MN 55110.
2. Information About Us 2.1 Our Site Broadrch.com is owned and operated by BroadReach Communications Inc a business registered in the State of Minnesota whose registered address is 441 Lake Avenue, St Paul, MN 55110 2.2 We are self-regulated and GDPR compliant
5. How Do We Use Your Data? 5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more those located in the EU. Details on security see section 6, below. 5.2 We use your data to provide the best possible services to you. This includes: 5.2.1 Providing information of value through strategies and tactics via email with the intent to aid in growing your business. 5.2.2 Providing and managing your access to Our Site in the case of a membership service where you are required to log-in 5.2.3 Personalizing and tailoring your experience on Our Site with Google Analytics 5.2.4 Supplying our services to you 5.2.5 Personalizing and tailoring Our services for you 5.2.6 Responding to communications from you via email or postal 5.2.7 Supplying you with email Insert Type of Email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by advising us by email or clicking on the unsubscribe link provided in the footer of our email communications). 5.2.8 On occasion we do market research by asking you for your feedback 5.2.9 Analyzing your use of Our Site [and gathering feedback] to enable Us to continually improve Our Site and your user experience 5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the [products and] services We can provide you without your consent for Us to be able to use such data. 5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015. 5.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies: a) you have given consent to the processing of your personal data for one or more specific purposes; b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract; c) processing is necessary for compliance with a legal obligation to which we are subject; d) processing is necessary to protect the vital interests of you or of another natural person; e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do We Store Your Data? 6.1 We only keep your data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct an annual review to ascertain whether we need to keep your data and ask if you are still interested in receiving out information. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are: 6.2 Your data will be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein) because we are a USA based business. You are deemed to accept and agree to this by using Our Site and submitting information to us. We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties 6.3 Data security is of great importance to us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site. 6.4 Steps We take to secure and protect your data include: 6.4.1 Our Secure 3rd party vendors: Lead Pages, Aweber, Google, Facebook, DRIP, GoDaddy 6.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data? 7.1 We may contract with third parties to supply [products and] services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with: LeadPages, Aweber, Facebook, Google 7.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymized and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law. 7.3 In certain circumstances we may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
9. How Can You Control Your Data? 9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details AND/OR by managing your Account). 9.2 You may also wish to sign up to one or more of the preference services operating in the United States. The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. How Can You Access Your Data? You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at Solutions@Broadrch.com.
14. Automated Decision-Making and Profiling 14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us. 14.2 The right described in section 14.1 does not apply in the following circumstances: a) The decision is necessary for the entry into, or performance of, a contract between the You and Us; b) The decision is authorized by law; or c) You have given you explicit consent. 14.3 Where We use your personal data for profiling purposes, the following shall apply: a) Clear information explaining the profiling will be provided, including its significance and the likely consequences; b) Appropriate mathematical or statistical procedures will be used; c) Technical and organizational measures necessary to minimize the risk of errors and to enable such errors to be easily corrected shall be implemented; and d) All personal data processed for profiling purposes shall be secured in order to e) prevent discriminatory effects arising out of profiling.
15. Email Policies (USA) We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties except as allowed in the section titled Disclosure of Your Information. We will maintain the information you send via e-mail in accordance with applicable US federal law. In compliance with the CAN-SPAM Act, all e-mails sent from our organization will clearly state who the e-mail is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.Our emails provide users the opportunity to opt-out of receiving communications from us and our partners by reading the unsubscribe instructions located at the bottom of any e-mail they receive from us at any time.Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the e-mail.