Effective: October 27, 2023
This Privacy Policy (the “Policy”) lists, and generally describes the policies and procedures related to, information and data Brand Federation, LLC (“Brand Federation”), a Virginia limited liability company (“we,” “us,” “our,” “our company”) collects from visitors to BrandFederation.com (our “Website”).
This Policy relates only to BrandFederation.com and our company, not to any third party site or service linked to our Website or recommended or referred by us or through our Website.
We, and/or our contractors, collect and store any information you choose to put in an email, contact form, or comment you send us (e.g., name, email address, telephone number, mailing address).
We, and/or our contractors, also collect data on how our Website is used and its visitors: for example:
We do not rent or sell your information. We do not share it with any third party unless necessary to fulfill a request or inquiry from you or required by law.
We use personal information for internal and marketing purposes. You may consent (or, “opt-in”) to receive our email communications – such as newsletters, events, timely alerts, or other promotional emails. Some “usage data” comes through “cookies” (basically small data files sent to your device when visiting our Website) and other technologies (we’ll refer to them collectively as “cookies” for convenience), as described below.
Our Website is not meant to collect information that may be considered “sensitive” (as various jurisdictions may use the term), nor from anyone under age 18. If nonetheless you know of potentially “sensitive,” or children’s information collected through our Website, please contact our Data Protection Officer, Rian Chandler-Dovis, at rian.chandler-dovis@brandfederation.com.
If you no longer wish to receive our email communications, you may opt-out by clicking “unsubscribe” in emails you receive from us.
If you wish to:
please contact our Data Protection Officer, Rian Chandler-Dovis, at rian.chandler-dovis@brandfederation.com.
We use your personal information to reply to messages you send us via email or through our contact forms or comments, to process your transactions with us, to otherwise correspond with you, and other legitimate business purposes such as security and fraud prevention. Also, if you send us a contact form or subscribe to our blog or opt-in to participate in a survey, we’ll put your name and email address and any other contact information you provide on our notices list(s), so that you get email or other notice of future blog posts and surveys from us. (You can unsubscribe when you receive one of those announcements, or at any time by contacting us at the email address below.)
As do most websites, ours uses cookies. Some are necessary for the website to operate, others we use to help improve and secure our website, others help us learn about and market to our visitors. If you visit our website from outside the United States, our cookie vendor is set to block non-essential cookies by default (with your option to grant consent via the cookie banner). Regardless of your location, you may also manage certain (non-essential) cookies by adjusting your browser settings. Do Not Track (“DNT”) is an optional setting in a web browser that expresses a preference that websites not track your online behavior elsewhere. We have enabled our cookie compliance vendor’s platform to respect DNT and Global Privacy Control browser settings. (If you have cookie-blocking browser settings, our website’s cookie banner may not show for you).
Particularly given the limited amount and type of information and data collected through our Website, we may or may not have identified all possible uses, or restricted contractors’ (see Section F, below) own use or disclosure of information or data. We are not responsible for the conduct or policies of our contractors (or their subcontractors).
Under certain circumstances, we may be required to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We retain your personal information so long as it serves the purposes listed in this Privacy Policy, including to send you blog post notices and other communications (unless you’ve unsubscribed), to collect and monitor traffic and other usage statistics at our Website, and to comply with our legal obligations.
We may store or process your data outside your city, province, state, or country, including through one of our contractors. Your personal information may be stored in a jurisdiction that operates under privacy and data protection laws different from (and potentially less protective than) those of your home jurisdiction. In cases where we transfer personal information to third parties, we may be potentially liable for those third parties in certain circumstances.
We may disclose personal information to attorneys or law enforcement authorities to address contract violations or illegal behavior, or to enforce our rights. We disclose information demanded in a court order, subpoena, or otherwise required by law, or to prevent harm to persons or property. And we may share personal information in connection with a corporate transaction, like a merger or sale of our company, the sale of most of our assets, or a bankruptcy.
As described above, our contractors (and their subcontractors) help us with Website hosting and storage, security and fraud prevention, monitoring Website use, communicating with and marketing to Website users and students, payment processing, and distance learning. We change contractors, and their roles, from time to time. Certain contractors (and their subcontractors) can access data we collect (or they collect as a result of our relationship with them), including personal information, some via cookies. With respect to cookies, you may be able to adjust your browser settings to notify you of cookies, or to refuse cookies. (It’s possible that if you don’t accept certain cookies, you may not be able to make as efficient or complete use of some websites, including ours. Do reach out if you are unable to access something you need from our Website, or are unable to complete a transaction with us, because of your cookie choices).
See our Website’s Cookie List here: https://www.BrandFederation.com/cookie-list/
A significant aspect of our business involves the collection of survey data to help our clients with their marketing and Branding strategies. We obtain “panels” (essentially lists) of possible survey participants from multiple sources. If you wish to be included in a panel, you can send us your contact information through this website. We will in turn verify your interest by sending you a confirmatory email to which you can respond by either “opting-in” or “opting-out.” If you opt-in, we may include you in a future survey. If you opt-out, we will not send you any further emails unless and until you opt-in again by contacting us. If you receive an email from us that you did not request, it will provide a link by means of which you can opt-out of that survey, or all future emails or texts. If you opt-out at any point, we may retain your email information for the sole purpose of ensuring that you do not receive further emails. If you prefer that we do not keep your email for any purpose, we will provide a link for that preference as well, but it leaves open the possibility that your email may appear in another panel obtained from a third party, and we would have no means of preventing an email from being sent to you. You would of course have the choice to opt-out again if you receive an unwanted or unsolicited email.
Google Analytics is a web analytics service that gathers information about our Website’s traffic and makes it available to us. This information may be used, for example, to understand and monitor Website use, and to assist with advertising. We use Google Adwords to advertise, and this may include advertising to Website users. If you are interested in Google’s privacy practices, and methods that may be available to you to of opt out of certain uses such as analytics and personalized advertising, visit: Google Analytics; Google Cookies.
We use HubSpot as our principal means of communicating with you and collecting the information we use in our business. Hubspot does not use this information for any reason not strictly related to providing the services we purchase from them. You can review HubSpot’s privacy policy here.
We store information you send us via email and through contact forms (such as your contact information, e.g., name, email address, telephone number, mailing address). We keep that information on password-protected computers and share it with trusted contractors.
We do not directly store the personal information that may be included in usage data collected by cookies and other mechanisms at our site (with exceptions described below). Data we don’t store ourselves is collected and stored by our contractors, under their policies and procedures. See Section F above for information about contractors and their policies.
Unfortunately, neither we nor any website can guarantee the security of personal information or other data, including during transmission and storage. Use of the Website and our distance learning offerings is at your own risk.
You can access and change contact information we store about you (i.e., email address) by emailing our Data Protection Officer, Rian Chandler-Dovis, at rian.chandler-dovis@brandfederation.com.
We provide this Policy in the interest of transparency to our Website users. Doing so is not intended to suggest, and does not mean that, legal responsibilities apply to Brand Federation that would not otherwise. Standards for personal information are not the same in all jurisdictions, inside and outside and among the United States, and are rapidly evolving and complex. Simply put, not all laws, including collection notice requirements, apply to all entities, individuals, or information, in all locations, or in all circumstances. We are committed to complying with all applicable data privacy laws to the best of our understanding of those laws and how they apply to our business.
Individuals in certain jurisdictions, both inside and outside the United States, have certain rights when entities governed by those laws process their “personal data” or “personal information” (for example, pursuant to the European Union’s General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA) the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (“CPA”), the Utah Consumer Privacy Act (UCPA), Connecticut SB6 (CDPA) and other international and U.S. State and federal laws now in force or soon to come into force). Depending on the jurisdiction, and subject to various limitations, such rights may include, for example, to access/obtain a copy, update/correct, or delete it; to object to/opt-out of certain processing (or not allow certain processing without affirmative consent); or to complain to a data protection authority. Entities which the CCPA defines as a “business” have special obligations to Californians including, for example, more detailed notices, and if personal information is “sold,” or “shared” (meaning for the CCPA, for certain behavioral advertising) the opportunity to opt-out. New consumer data privacy laws continue to emerge and we will endeavor to keep track and reference them here.
The Federal Trade Commission has jurisdiction over Brand Federation’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).
Brand Federation complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Brand Federation has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Brand Federation has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/ .
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Brand Federation commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S.DPF, and the Swiss-U.S. DPF should first contact Brand Federation at: rian.chandler-dovis@brandfederation.com.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and/or the Swiss-U.S. DPF, Brand Federation commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and/or the Swiss-U.S. DPF to the ANA DPF Dispute Resolution, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.ana.net/content/show/id/accountability-dpf-consumers for more information or to file a complaint. The services of ANA DPF Dispute Resolution are provided at no cost to you.
Under certain circumstances, individuals may invoke binding arbitration to resolveDPF complaints not resolved by any other means.
Under your applicable privacy laws and regulations (the “Applicable Law”), and subject to certain exceptions and limitations, you can contact Brand Federation to exercise the rights described below with respect to certain personal information that Brand Federation holds about them. To the extent those rights apply to you, they are described below. Brand Federation also handles certain personal information on behalf of Brand Federation customers. You should contact those customers to exercise any rights you may have with respect to that personal information.
You have the right to request that we provide you with details about the personal information we collect, use, disclose and sell. You can submit a verifiable consumer request to our Data Protection Officer, Rian Chandler-Dovis, at rian.chandler-dovis@brandfederation.com. Brand Federation reserves the right to verify your identity to our satisfaction. You are entitled to receive the following:
Because Brand Federation has disclosed or sold (as those words are defined in the Applicable Law) personal information to third parties in the last 12 months, you are also entitled to receive the categories of personal information that Brand Federation has disclosed or sold in the past 12 months
You have the right to request deletion of the personal information we have collected about you (subject to some exceptions). You can submit your request as described above, and we reserve the right to conduct the verification described above.
You have the right not to receive unlawful discriminatory treatment by Brand Federation for the exercise of your privacy rights under the Applicable Law.
You have the right to opt-out of the sale of your personal information or to limit the use and disclosure of sensitive personal information by Brand Federation. You can submit a verifiable consumer request to opt-out to our Data Protection Officer, Rian Chandler-Dovis, at rian.chandler-dovis@brandfederation.com.
Brand Federation collects personal information from research participants during and after registration with a panel, including, without limitation, during participation in a survey and in connection with the receipt and redemption of rewards and incentives and/or during the Application/Services registration and download process.
The categories of personal information we may collect include:
All of the information above was collected for the purposes described above in Part C. In Applicable Law terms, these purposes, which are described further in that section of our Privacy Policy, include but are not limited to the following examples:
Brand Federation has not sold any of the above categories of personal information in the last 12 months.
Brand Federation has not disclosed any of the above categories of personal information in the last 12 months.
Survey Fielding Providers such as:
Brand Federation may share Personal Information with other similar providers and may update this list from time to time. [Upon request, we will provide the names of such providers with whom we shared your information.]
If you wish to:
or if you have any questions regarding Brand Federation's privacy practices and/or this Policy, please contact our Data Protection Officer, Rian Chandler-Dovis, at rian.chandler-dovis@brandfederation.com.
We may change this Privacy Policy at any time by posting a new version on this page or on a successor page. The new version will become effective on the date it is posted, which will be listed at the top of the page as the new Effective Date. Each time the Website is accessed, users are urged to view (and are deemed to have accepted and agreed to) the Policy.
We value your privacy and security. We take appropriate measures to protect your personal data from unauthorized access. We use third-party providers/services that encrypt data-at-rest and in-transit using industry-standard encryption protocols.
For questions about this Privacy Policy, or to unsubscribe from marketing emails, please contact our Data Protection Officer, Rian Chandler-Dovis, at rian.chandler-dovis@brandfederation.com. Please reach out if you are unable to access something you need from our Website, or are unable to complete a transaction with us, because of your cookie choices. In communications with us, please do not provide us personal information about others (unless you have their permission), and never provide us more personal information than necessary (including in comments). Finally, we strive to keep the Website reasonably accessible to users with disabilities, but do contact us if you require a reasonable accommodation.
If you believe you have legal rights you wish to exercise regarding your personal data, contact our Data Protection Officer, Rian Chandler-Dovis, at rian.chandler-dovis@brandfederation.com. We strive to evaluate such requests and comply to the extent required under then-applicable law, and may request that you identify the law you believe applies to you. (Brand Federation is a small, U.S.-based entity, with modest types and amounts of personal data processing, and does not believe it falls within most, if any, of such laws’ pre-requisites for coverage. For example only, Brand Federation does not satisfy the threshold to be regulated as a CCPA “business”). Regardless, as noted above you can access and change contact information we store about you by emailing us.
