California Privacy Disclosure: Brasco Enterprises does not track its clients, visitors or users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. Third parties that have content embedded on Brasco Enterprises’ websites such as a social feature or a stock ticker may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific Brasco Enterprises website from a certain IP address. Third parties cannot collect any other personally identifiable information from Brasco Enterprises’ websites unless you provide it to them directly.
Our Privacy Policy Updated June 1, 2018
Brasco Enterprises (“Brasco Enterprises”, “Brasco”, “we,” “our,” and “us” refers to Brasco Enterprises, LLC, an American entity, formatted under the laws of the State of California, United States of America) is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, Brasco Enterprises is committed to the appropriate protection and use of personal information (sometimes referred to as “personally identifiable information” or “PII”) that has been collected online.
Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals or offer information about employment opportunities. Please review this Privacy Statement (“Privacy Statement”) to learn more about how we collect, use, share and protect the PII that we have obtained.
1. Collection and use of personal information
1.1. What information we collect
We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you will have previously provided your personal information to Brasco Enterprises (if, for example, you are a former employee). If you choose to register or login to a Brasco Enterprises website using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, Facebook or Twitter) with Brasco Enterprises, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect will depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.
When you register or submit personal information to Brasco Enterprises we will use this information in the manner outlined in this privacy statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a Brasco Enterprises website and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third-party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other Brasco Enterprises sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with Brasco Enterprises, we will use the information that you provide to match you with available Brasco job opportunities.
In some cases where you have registered for certain services we will store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).
1.2 The legal grounds we have to use your personal information
Brasco Enterprises generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.
The law in Europe allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:
- Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
- Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
- Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
- Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting us at administration@brasco.enterprises.
Examples of the ‘legitimate interests’ referred to above are:
- To offer information and/or services to individuals who visit our web site or offer information about employment opportunities.
- To prevent fraud or criminal activity and to safeguard our IT systems.
- To customize individuals’ online experience and improve the performance, usability and effectiveness of our online presence.
- To conduct, and to analyze, our marketing activities.
- To meet our corporate and social responsibility obligations.
- To exercise our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property.
In some cases, the personal data that we collect will also include special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences in each case where permitted by law.
1.3 Automatic collection of personal information
In some instances, Brasco and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of our online presence, and to measure the effectiveness of our marketing activities.
1.3.1 IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.
1.3.2 Cookies
Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.
On some of our websites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites’ features.
Further information about managing cookies can be found in your browser’s help file or through sites such as www.allaboutcookies.org.
Other third-party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.
BY NAVIGATING ON OUR WEBSITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.
1.3.3 Google Analytics
We use Google Analytics.
More information about how Google Analytics is used by Brasco Enterprises can be found at http://www.google.com/analytics/learn/privacy.html.
1.3.4 Web beacons
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. We may only use web beacons in accordance with applicable laws.
Brasco Enterprises or its service providers may use web beacons to track the effectiveness of third-party websites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.
You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address, but cookie information will not be recorded.
In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.
1.3.5 Location-based tools
Brasco Enterprises may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
1.4 Social media widgets and applications
Our websites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use our websites (see details on ‘Social Sharing’ cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
In addition, our websites may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any Brasco Enterprises social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.
1.5 Children
We understand the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children. It is our policy never to knowingly collect or maintain information about anyone under the age of 18.
2. Sharing and transfer of personal information
2.1 Transfer within the network of Brasco Enterprises Associate Business Partners or Firms, or of Our Network Firms
We share information about you with other member firms and/or Business Partners of the Brasco Enterprises network as part of international engagements, where required or desirable to meet our legal and regulatory obligations around the world. Other parts of our network are also used to provide services to us and you, for example hosting and supporting IT applications, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run our business.
2.2 Transfers to third parties
We do not share personal information with third-parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. In addition, Brasco Enterprises will transfer certain personal information outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement.
Brasco Enterprises will also typically store personal information outside of the EEA. If we do this your personal information will continue to be protected by means of contracts we have in place with those organizations outside the EEA, containing standard data protection clauses which are in a form approved by the European Commission.
Brasco Enterprises will not transfer the personal information you provide to any third parties for their own direct marketing use.
3. Choices
In general, you are not required to submit any Personally Identifiable Information (“PII”) to Brasco Enterprises online, but we may require you to provide certain PII in order for you to receive additional information about our services and events. We may also ask for your permission for certain uses of your PII, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.
As described in “Cookies” above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.
4. Your rights
If Brasco Enterprises processes personal information about you, you have the following rights:
- Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.
- Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more.
- Other Rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.
You can make a request or exercise these rights by contacting us at administration@brasco.enterprises and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
5. Data security and integrity
Brasco Enterprises has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite our best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.
We also make reasonable efforts to retain personal information only for so long (i) as the information is necessary to comply with an individual’s request, (ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or (iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to requirements of (i) and (iii) above, personal information will not be retained for more than two (2) years.
6. Links to other sites
Please be aware that Brasco Enterprises websites may contain links to other sites, including sites maintained by other Brasco Enterprises business partners or associated firms and affiliated companies that are not governed by this Privacy Statement, but by other privacy statements that will often differ somewhat. We encourage users to review the privacy policy of each web site visited before disclosing any personal information.
By registering on any of our website and then navigating to another Brasco Enterprises website while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the Brasco website you are visiting.
7. Changes to this statement
We may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. Any changes to the processing of personal information as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.
8. Policy questions and enforcement
Brasco is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at administration@brasco.enterprises. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.
