Brightfin Privacy Policy

Last modified: April 14, 2025

Introduction

This Privacy Policy (“Privacy Policy”) is entered into between MobiChord, Inc. d/b/a brightfin on behalf of itself and its affiliates, including but not limited to Mobile Solutions Services Holdings, LLC (“brightfin” or “We”) and anyone who accesses www.brightfin.com (“You”) and/or customers that use our services (“Website:”) our “(“Customer” or “You”)”) or uses our services (the “Services(s)”), and supplements the Terms of Use (located at www.brightfin.com/termsofuse), and if applicable the Master Ordering Agreement in effect between brightfin and Customer under which brightfin is providing the Services to Customer (collectively referred to as the “Agreement”).

We respect Your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy describes the types of data We may collect from You when You visit the Website and/or use the Services and our practices for collecting, using, maintaining, protecting, and disclosing that data. Please read this Privacy Policy carefully to understand our policies and practices regarding Your data and how We will treat it. If You do not agree with our policies and practices, Your choice is not to use our Website and/or the Services. By accessing or using this Website and/or the Services, You agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website and/or the Services after We make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Data We Collect About You and How We Collect It

This Privacy Policy applies to data We collect:

• By which You may be personally identified, such as name, postal address, email address, telephone number any other identifier by which You may be contacted online or offline (“Personal Data“);
• That is about You but individually does not identify You, such as aggregated data (including general traffic, site usage, length-of stay, etc.);
• About Your internet connection, the equipment You use to access our Website, and usage details.
• Provided by You directly to us:
  • When You create an account or use our interactive tools and the Services;
  • When You voluntarily provide information in connection with the Services or through responses to surveys or questionnaires;
  • In email, text, and other electronic messages between You and this Website, or through the Services, including live chat (via Tawk.to);
  • Through the online application process, including resumes and other application-related documents provided by You;
  • When You send an email or otherwise contact us.
• When You use the Website or Services, and such information is collected automatically:
  • Through Cookies (see below);
  • If You use a location-enabled browser, We may receive information about Your location;
  • If You download and install certain applications and software We make available, We may receive and collect information transmitted from Your computing device for the purpose of providing You the relevant Services, such as information regarding when You are logged on and available or receive updates or alert notices.
• Through third parties, such as Google Analytics;

Personal Data

This Privacy Policy covers how We treat Personal Data that We gather when You access or use our Website or Services. For purposes of this section, “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal data” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies We don’t own or control or people We don’t manage.Categories of Personal Data We Collect

This chart details the categories of Personal Data that We may collect and may have collected over the past 12 months:

Category of Personal Data	Examples of Personal Data We Collect	Categories of Third Parties with Whom We Share this Personal Data
Profile or Contact Data	–        First and last name –        Email	–        Services Providers –        Analytics Partners –        Parties You Authorize, Access or Authenticate
Device/IP Data	–        IP address –        IP-address based location information –        Device ID –        Type of device/operating system/browser used to access the Website or the Services –        Other applications that utilize the microphone partner	–        Analytics Partners –        Parties You Authorize, Access, or Authenticate
Web Analytics	–        Web page interactions –        Referring webpage/source through which You accessed the Services	–        Analytics Partners –        Parties You Authorize, Access, or Authenticate
Social Network Data	–        Social media profiles	–        Services Providers –        Parties You Authorize, Access, or Authenticate
Professional or Employment-Related Data	–        Job title and role –        Employer –        Personal website	–        Services Providers –        Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide	–        Identifying Information in emails, letters, texts, or other communication You send us –        Calendar data, including but not limited to meeting invitations, body text, and sender and recipients –        Meeting data, including but not limited to attendees, audio, and transcriptions –        Any other identifying information You authorize brightfin to access or elect to share with brightfin –        Any derivatives of such data	–        Services Providers –        Analytics Partners –        Parties You Authorize, Access, or Authenticate

 

Google API Data

Notwithstanding the foregoing, to the extent We collect Personal Data about You through use of a Google API, our use and transfer of such Personal Data to any other third-party will be in compliance with the Google API Servicess User Data Policy, including the Limited Use Requirements.

Information We Collect Through Automatic Data Collection Technologies 

As You navigate through and interact with our Website, We may use automatic data collection technologies to collect certain information about Your equipment, browsing actions, and patterns, including:

• Details of Your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that You access and use on the Website.
• Information about Your computer and internet connection, including Your IP address, operating system, and browser type.

The information We collect automatically only includes statistical data and does not include Personal Data, but We may maintain it or associate it with Personal Data We collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about Your preferences, allowing us to customize our Website according to Your individual interests.
• Speed up Your searches.
• Recognize You when You return to our Website.

The technologies We use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of Your computer. You may refuse to accept browser cookies by activating the appropriate setting on Your browser. However, if You select this setting You may be unable to access certain parts of our Website. Unless You have adjusted Your browser setting so that it will refuse cookies, our system will issue cookies when You direct Your browser to our Website. For information about managing Your privacy and security settings for cookies, see Choices About How We Use and Disclose Your Information. We use the following cookies on our Website:

Cookie Name	Primary Purpose	Type / Duration
visitor_id309431-hash /	VisitorTrack is a cookie used by a third party provider that helps us monitor site traffic and use. This process includes the collection of IP addresses and search-related data in order to evaluate visits to, and monitor use of, the site.	Up to 24 months
FB_cookie fr	These cookies are used to deliver advertisement 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 the advertising campaign.	Up to 30 days
PHPSESSID	PHPSESSID cookies contain a reference to a session stored on the web server. No information is stored in the user’s browser and this cookie can only be used by the current web site.	Session
_ga	Used to distinguish users and collect Google Analytics data	Up to 24 months
_gid	Used to distinguish users and journeys.	Up to 1 day
rcc_accepted	This cookie remembers Your choice to click ‘Accept’ on our cookie policy banner which appears the top of the page. It has the purpose of preventing the cookies confirmation button from appearing in new sections of the same user.	Until user clears browser’s cache
test_cookie	DoubleClick uses cookies to serve adverts on third party websites. The DoubleClick cookie serves relevant ads to potential customers and gathers information about how or if You are interacting with these ads. This cookie tests for cookie setting permissions for Google Analytics and is used to check if the user’s browser supports cookies.	Up to 1 day
BizoID	LinkedIn Ad analytics. Comes from: LinkedIn insights and ads tags. The BizoID cookie stores a unique LinkedIn user ID. Note: The LinkedIn user ID does not contain personally identifiable information. This cookie is used to determine if there is Bizographic data attached to this visitor.	Up to 6 months
UserMatchHistory	Used for LinkedIn Ad analytics.	Up to 6 months
Lang	Remembers the user’s selected language version of a website.	Session
bscookie bcookie lidc	Secure browser ID cookies. Used by LinkedIn for tracking the use of embedded services, including the Linkedin follow, sharering content, and apply within Linkedin features. These cookies include access to social networks in order to connect with and to share certain contents from the portal so that the user does not have to register whenever a connection is made. The information is only stored in the social networks. This is used for Sign-in with Linkedin.	Up to 2 years or until user clears browser’s cache

 

• Web Beacons. Pages of Our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the brightfin, for example, to count users who have visited those pages and for other related website statistics.

How We Use Your Personal Data

We use Personal Data that We collect about You or that You provide to us, including any Personal Data:

• To present our Website and its contents to You.
• To provide You with information, products, or Services that You request from us.
• To constantly improve our website.
• To identify You as our contractual partner.
• To invoice our fees.
• To carry out our obligations and enforce our rights arising from any contracts entered into between You and us, including for billing and collection.
• To notify You about changes to our Website or any products or services We offer or provide though it.
• To allow You to participate in interactive features on our Website.
• To fulfill any other purpose for which You provide it.
• In any other way We may describe when You provide the information.
• For any other purpose with Your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that We collect or You provide as described in this Privacy Policy:

• To Services Providers. These parties help us provide the Services or perform business functions on the Website or our behalf. They include:
  • Hosting, technology and communication providers.
  • Security and fraud prevention consultants.
  • Support and customer service vendors.
  • Product fulfillment and delivery providers.
  • Audio transcription providers and processors.
• To Analytics Partners, such as Google LLC, ServiceNow, Inc., and Amazon Web Services, Inc. These parties provide analytics on the Website or usage of the Services. They include:
  • Companies that track how users found or were referred to the Services.
  • Companies that track how users interact with the Website or Services.
• To parties You Authorize, Access, or Authenticate, including but not limited to:
  • Organizations through which You access our Services (such as Your employer);
  • Third parties You access through the Services; or
  • Social media services.
• To our subsidiaries and affiliates.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of brightfin assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by brightfin about our Website users is among the assets transferred.
• To fulfill the purpose for which You provide it (for example, submitting a request for more information via the chat function on the Website).
• For any other purpose disclosed by us when You provide the information.

We may also disclose Your Personal Data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use (located at https://www.brightfin.com/website-terms-of-use/and other agreements), including for billing and collection purposes.
• If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of brightfin, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide You with choices regarding the Personal Data You provide to us. We have created mechanisms to provide You with the following control over Your information:

• Tracking Technologies. You can set Your browser to refuse all or some browser cookies, or to alert You when cookies are being sent. You may also refuse cookies via pop-up box when prompted when visiting the Website. If You disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any Personal Data to or on the Website. We do not knowingly collect Personal Data from children under 16. If You are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about Yourself to us, including Your name, address, telephone number, email address, or any screen name or user name You may use. If We learn We have collected or received Personal Data from a child under 16 without verification of parental consent, We will delete that information. If You believe We might have any information from or about a child under 16, please contact us at privacy@brightfin.com.

How to Contact Us

Please direct any questions or comments about this Privacy Policy or privacy practices to privacy@brightfin.com You may also write to us via postal mail at:brightfin
ATTN: Legal Department
8310 South Valley Highway, Suite 470
Englewood, Colorado 80112
United States of America

Enforcement; Recourse: We urge You to contact us to find a solution for any concern You may have about our data practices; however, applicable law may permit You to lodge a complaint with Your competent data protection authority (i.e., the authority of Your place of habitual residence, place of work, or place of alleged infringement).

State Resident Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Data.

If You are a resident of Colorado, Connecticut, Virginia, and Utah, You have the right to:

• Confirm whether We process their Personal Data;
• Access and delete certain Personal Data;
• Data portability; and
• Opt-out of Personal Data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their Personal Data, taking into account the information’s nature processing purpose; and
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please contact us at privacy@brightfin.com with the subject line “[Your State] Privacy Rights Request” and providing us with Your name and the email address associated with Your account.

California Resident Rights

This “California Resident Rights” section applies only to individuals residing in California. California residents have certain rights with respect to their Personal Data, including:

• The right to access, including the right to know the categories and specific pieces of Personal Data We collect;
• The right to deletion of Your Personal Data, subject to certain limitations under applicable law;
• The right to request disclosure of data collected;
• The right to disclosure of data disclosed for valuable consideration;
• The right to opt out of sales of Personal Data;
• The right not to be discriminated against for exercising certain rights under California law; and
• Under California’s “Shine the Light” law, California residents who provide Personal Data in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year data about the customer data We shared, if any, with other businesses for their own direct marketing use. If applicable, this data would include the categories of customer data and the names and addresses of those businesses with which We shared customer data for the immediately prior calendar year (e.g., requests made in 2020 will receive data regarding 2019 sharing activities). Please be aware that not all sharing activities are covered by the Shine the Light law and only covered data will be included in our response.

To exercise any of these rights please mail us at our postal address provided above, or contact us at privacy@brightfin.com with the subject line “California Privacy Rights Request” and providing us with Your name and the email address associated with Your account. Please be as specific as possible in relation to the Personal Data You wish to access. Once We receive Your request, We will review it, determine whether We can verify Your identity, and process the request accordingly. If We need additional data to verify Your identity, We will let You know. We will respond to Your request within 60 days of receipt, or notify You if We require additional time. If You would prefer, You may designate an authorized agent to make a request on Your behalf.

Nevada Resident Rights

If You are a resident of Nevada, You have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by mailing us at our postal address provided above or contacting us at privacy@brightfin.com with the subject line “Nevada Do Not Sell Request” and providing us with Your name and the email address associated with Your account.

European Union, United Kingdom, and Swiss Data Subject Rights

If You are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, You may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to Your personal Data, as outlined below.

Personal Data: References to “Personal Data” in this Privacy Policy are equivalent to “Personal Data” governed by European data protection legislation.

Processor: brightfin is the “processor” of Your Personal Data covered by this Privacy Policy for purposes of European data protection legislation.

Controller: Customer is the “controller” of Your Personal Data covered by this Privacy Policy for purposes of European data protection legislation.

Legal bases for processing: We use Your Personal Data only as permitted by law. Our legal bases for processing the Personal Data described in this Privacy Policy are described in the table below.

Processing Purpose: Details regarding each processing purpose listed below are provided in the section above titled “How We Use Your Personal Data”.

Legal basis to operate the Services: Processing is necessary to perform the contract governing our provision of the Services or to take steps that You request prior to signing up for the Services. If We have not entered into a contract with You, We process Your Personal Data based on our legitimate interest in providing the Services You access and request:

• For research and development;
• To send You marketing communications;
• To manage our recruiting and process employment applications;
• For compliance, fraud prevention and safety; and
• To create anonymous data.

These activities constitute our legitimate interests. We do not use Your Personal Data for these activities where our interests are overridden by the impact on You (unless We have Your consent or are otherwise required or permitted to by law).

To comply with law: Processing is necessary to comply with our legal obligations.

With Your consent: Processing is based on Your consent. Where We rely on Your consent You have the right to withdraw it any time in the manner indicated when You consent or in the Services.

Use for new purposes: We may use Your Personal Data for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which We collected it. If We need to use Your Personal Data for an unrelated purpose, We will notify You and explain the applicable legal basis.

 

Sensitive Personal Data: We ask that You not provide us with any sensitive Personal Data (e.g., data related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us. If You provide us with any sensitive Personal Data to us when You use the Services, You must consent to our processing and use of such sensitive Personal Data in accordance with this Privacy Policy. If You do not consent to our processing and use of such sensitive Personal Data, You must not submit such sensitive Personal Data through our Services.

Automated Decision-Making and Profiling: We may use automated decision-making and/or profiling in regard to Your Personal Data for some services and products, for example You may be matched with other users of the service for a video conversation based on the data You provided about Yourself.

Retention: We retain Personal Data for as long as necessary to fulfill the purposes for which We collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for Personal Data, We consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Your Personal Data, the purposes for which We process Your Personal Data and whether We can achieve those purposes through other means, and the applicable legal requirements. When We no longer require the Personal Data We have collected about You, We will either delete or anonymize it or, if this is not possible (for example, because Your Personal Data has been stored in backup archives), then We will securely store Your Personal Data and isolate it from any further processing until deletion is possible. If We anonymize Your Personal Data (so that it can no longer be associated with You), We may use this data indefinitely without further notice to You.

Certain rights: You have certain rights regarding Your Personal Data. If You are located within or outside of the European Union, You may ask us to take the following actions in relation to Your Personal Data that We hold:

• Access: Provide You with data about our processing of Your Personal Data and give You access to Your Personal Data.
• Correct: Update or correct inaccuracies in Your Personal Data.
• Delete: Delete Your Personal Data.
• Transfer: Transfer a machine-readable copy of Your Personal Data to You or a third party of Your choice.
• Restrict: Restrict the processing of Your Personal Data.
• Object: Object to our reliance on our legitimate interests as the basis of our processing of Your Personal Data that impacts Your rights.

To exercise any of these rights please mail us at our postal address provided above, or contact us at privacy@brightfin.com with the subject line “EU Privacy Rights Request” and providing us with Your name and the email address associated with Your account. We may request specific data from You to help us confirm Your identity and process Your request. Applicable law may require or permit us to decline Your request. If We decline Your request, We will tell You why, subject to legal restrictions. If You would like to submit a complaint about our use of Your Personal Data or our response to Your requests regarding Your Personal Data, You may contact us or submit a complaint to the data protection regulator in Your jurisdiction. You can find Your data protection regulator here.

If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If You have any questions about this section or whether any of the following applies to You, please contact us at privacy@brightfin.com.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If We make material changes to this Privacy Policy, We will notify You by updating the date of this Privacy Policy and posting it on the Website. We may, and if required by law will, also provide notification of changes in another way that We believe is reasonably likely to reach You, such as via e-mail (if You have an account where We have Your contact data) or another manner through the Services.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Services or Website (or as otherwise indicated at the time of posting). In all cases, Your continued use of the Services or Website after the posting of any modified Privacy Policy indicates Your acceptance of the terms of the modified Privacy Policy.