Global Privacy Policy

General Policy

This Privacy Policy is effective as of and was last updated on September 21, 2016.

1.   Who We Are

BROWZ is the collective name for the group of companies whose parent is BROWZ LLC, a limited liability company incorporated in the United States of America. The subsidiaries of BROWZ LLC include BROWZ Canada ULC in Canada (“BROWZ Canada”), Browz Europe Limited in the United Kingdom (“BROWZ UK”), BROWZ Germany GmbH (“BROWZ Germany”) and BROWZ Australia Pty Ltd in Australia (“BROWZ Australia”).

When we refer to ‘’we’’, “us” or ‘’our’’ we are referring to BROWZ and all of its subsidiaries.

We at BROWZ created this Global Privacy Policy (“Privacy Policy”) because we know that our customers care about how information they provide to us is used and shared. This Privacy Policy explains the conditions under which and the purposes for which we collect and use your Personal Information (as defined in Section 3 below) in connection with your use of our website at www.browz.com (“Site”), the BROWZ application (“App”), our service platform called the “BROWZ Supply Chain Verification Service” or any successor service platform (“Verification Service”), the third parties to whom we disclose your Personal Information, and the choices and means, if any, we offer you for limiting the use and disclosure of your Personal Information. The Site, App and Verification Service will be referred to collectively herein as the “Services”.  We will provide you with notice of such practices in clear and conspicuous language when you are first asked to provide Personal Information to us, or as soon as practicable thereafter, and in any event before: (a) we use your Personal Information for a purpose other than that for which it was originally collected; (b) your Personal Information is processed by a transferring organization; or (c) we disclose your Personal Information for the first time to a third party. As discussed in this Privacy Policy, we will disclose your Personal Information as described in Section 5 (How We Disclose Your Information/Onward Transfer).

BROWZ is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with applicable laws and regulations concerning the protection of personal information.  The procedures for modifying or changing this Privacy Policy in the future are discussed in Section 9 (“Changes to this Privacy Policy”) below.

The BROWZ Services are currently free of charge, but we reserve the right to charge fees for any or all of the BROWZ Services in the future.

2.   Important Information for Non-U.S. Residents

A.   U.S. and Non-U.S. Residents

The General Policy part of this Privacy Policy applies to use of the BROWZ Services around the world but, in particular, to use of the BROWZ Services from within the United States of America. If you are using the BROWZ Services from outside the United States of America, Schedule 1 of this General Policy contains Country Annexes that may be relevant to you. A Country Annex to this General Policy that may apply to you may take precedence over the General Policy part of this Privacy Policy. Please ensure that you also read any Country Annex to this General Policy that may be relevant to you.

B.   Non-U.S. Resident Data Transfer

If you are located outside of the United States, please be aware that any information you provide to us, including Personal Information (defined in Section 3 below), may be transferred to the United States of America. By providing us with any Personal Information, you consent to this transfer.

C.   EU-U.S. Privacy Shield Framework Principles

We abide by the ”EU-U.S. Privacy Shield Framework Principles” developed by the U.S. Department of Commerce and the European Commission and issued by the Department of Commerce on August 1, 2016. For details about the EU-U.S. Privacy Shield Framework Principles (“Privacy Shield Principles”) and a list of those U.S. entities that have self-certified to comply with the Privacy Shield Principles, go to the website at www.privacyshield.gov.  This Privacy Policy sets forth the Privacy Shield Principles that we follow with respect to transfers of Personal Information (as defined in Section 3 below) from the European Economic Area (“EEA”) to the United States.  For purposes of this Global Privacy Policy, references to the EEA and applicability of the Privacy Shield Principles will also include Iceland, Liechtenstein and Norway.

3.   Information We Collect

A.   General

We collect both Non-Personal Information and Personal Information from you. “Non–Personal Information” is information that, without the aid of additional information, cannot be directly associated with a specific person or entity. “Personal Information,” by contrast, is information such as first name; last name; address, including street name and number, city, state, postal or zip code and country; home or mobile phone number; email address; and such other information that you choose to provide to us in your sole discretion from time to time, that without more, can identify a specific living person, individual or entity.

B.   Collection of Personal Information

When you are required to sign up to use certain  BROWZ Services, you may be asked to provide us with certain Personal Information, such as your name, telephone number, company name (if applicable), and email address. If you submit documents to us, we will collect the Personal Information that is on those documents. The functionality of the BROWZ Services, and our other Services may change from time to time and we specifically reserve the right to make such changes.

i.    Modifying Your Profile

If you want to make any changes to the Personal Information in your profile, please log on to the full BROWZ application on your desktop, and use the tools provided to modify your Personal Information.

B.   Collection of Non-Personal Information

Like most app operators, we use automatic data collection technology when you use the BROWZ Services to record information that identifies your device, to track your use of our BROWZ Services, and to collect certain basic information about you and your usage habits. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of the BROWZ Services you visit, and similar information concerning your use of the BROWZ Services (the “Usage Information”). We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs).

i.    Cookies

Cookies are small packets of data that the BROWZ Services store on your device so that your device will “remember” information about your visit. We may use cookies to track the pages that you visit during each BROWZ Service session, both to help us improve your experience and to help us understand how the BROWZ Services are being used.

IF YOU DO NOT WISH TO HAVE COOKIES PLACED ON YOUR DEVICE, YOU SHOULD SET YOUR BROWSER TO REFUSE WEB COOKIES BEFORE ACCESSING THE BROWZ SERVICES, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE BROWZ SERVICES MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF COOKIES. IF YOU REFUSE COOKIES, YOU ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

ii.   Clear Gifs

Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of BROWZ Services users. It is usually invisible to you but allows us to check whether you have viewed a particular page or communication. We may place clear gifs on pages of the BROWZ Services and in emails we send to you.

You may not decline clear gifs. However, they may be rendered ineffective by declining all cookies or modifying your browser setting to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis.

C.   Sensitive Personal Information

BROWZ does not collect, hold or otherwise process the following types of personal information:

  • your racial or ethnic origin;
  • your political opinions;
  • your religious or philosophical beliefs or other beliefs of a similar nature;
  • whether you are a member of a trade union;
  • information relating to your physical or mental health or condition;
  • information about your sexual life; and
  • information about whether you have committed or have been alleged to commit a criminal offense or any information relating to any legal proceedings about such offense or alleged offense.

4.   How We Use Your Information

A.   Personal Information

We will use your Personal Information for any purpose related to our business, including without limitation the following: (i) to respond to your requests and to provide you with the BROWZ Services and related services; (ii) to respond to your inquiries and contact you about changes to the BROWZ Services; (iii) to send you notices (for example, in the form of e-mails, mailings, and the like) regarding products or services you are receiving; (iv) for billing and collection purposes; (v) to improve the BROWZ Services; (vi) to contact you regarding other products or services we offer; (vii) to carry out our obligations and to enforce our rights arising from any or all contracts entered into between you and us; (viii) for any other purposes disclosed at the time the information is collected or to which you consent; or (ix) as otherwise specifically described in this Privacy Policy.

We may also use cookies and other information to enable us to customize your user experience.

B.   Data Integrity and Purpose Limitation

We will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you as set forth in this Privacy Policy. We will take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete, and current.

C.   Non-Personal Information

We analyze Non–Personal Information gathered from BROWZ Services users to help us better understand how the BROWZ Services are being used. By identifying patterns and trends in usage, we are able to better design the BROWZ Services to improve your experiences, both in terms of content and ease of use. We link information gathered using Non-Personal Information to Personal Information. Automatic data collection may be performed on our behalf by our services providers.

D.   How long will my personal information be kept?

We will hold your personal information on our systems for as long as is relevant for the purposes of processing in connection with the purpose for which it was collected for the applicable activity, or as long as is set out in any relevant contract you hold with us, or as further set out in our corporate retention schedule (a database that defines which documents should be kept and for how long).

5.   How We Disclose Your Information/Onward Transfer

A.   Personal Information

As described in Section 3 (“Information We Collect”), users may, at their option, disclose their own Personal Information by any means they choose. We will disclose Personal Information in the following circumstances:

i.    Surveys

From time to time, we may ask you to participate in surveys for our general business and marketing purposes. Participation in any survey is entirely voluntary.  Any Personal Information provided to us in connection with a survey will be used by us and disclosed to third parties (that are not bound by this Privacy Policy) solely for the limited and specified purposes of the survey, and only in non-personally-identifying, aggregated form.

ii.   Contests, Giveaways and other Promotions

From time to time, we may offer you the opportunity to participate in contests, giveaways and other promotions, which may be offered by us or by third parties. You will be given the option to consent to the use of your Personal Information at the time you sign up for the promotion.  Any information submitted by you in connection with promotions will only be shared for the limited and specified purpose of the promotion and will be subject to the terms of the promotion, and to the terms of our Privacy Policy if we offer the promotion. If a third party is running the promotion, we will enter into a contract with them in order to provide that (a) they will use Personal Information for limited and specified purposes consistent with the consent provided by you to them, and (b) they provide the same level of protection as the Privacy Shield Principles.  You will not be required to participate in any promotion.

iii.  Employees, Third-Party Processors and Third-Party Service Providers

We will disclose Personal Information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers who process Personal Information on our behalf, participate with us in the provision or operation of the BROWZ Services, or provide you with services.  If these entities process Personal Information inconsistent with the Privacy Shield Principles, we will remain responsible for compliance with the Privacy Shield Principles unless we are not responsible for the event giving rise to the damage.  We require service providers to whom we disclose Personal Information to contractually agree to provide at least the same level of protection for Personal Information as is required by the relevant Privacy Shield Principles.  The Country Annexes to this Privacy Policy set out our contractual arrangements with service providers that we use that are subject to the European Union Data Protection Directive.

iv.  By Law, to Protect Rights and to Comply with Our Policies

In the United States of America, we disclose Personal Information if: (a) required to do so by law including by statute, government regulation, or case law that creates conflicting obligations or explicit authorizations, provided that, in exercising any such authorization, an organization can demonstrate that its non-compliance with the Privacy Shield Principles is limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization;, or in response to a subpoena or court order; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; (c) we believe that you have abused the service or BROWZ Services by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws; (d) necessary to the extent and for the period necessary to meet national security, public interest, government regulation, or statutory or law enforcement requirements; (e) required to comply with legal obligations or legitimate accounting activities; (f) there is a need for confidentiality connected with possible acquisitions, mergers, joint ventures or other similar transactions carried out by investment bankers or auditors; (g) case law applies that creates conflicting obligations or authorizations for us; or (h) the effect of the European Directive or an EU Member State law is to allow exceptions or exemptions in a comparable situation.

The laws of other countries may require us to disclose Personal Information in certain circumstances.

v.  Business Transfers; Bankruptcy

We reserve the right to transfer all Personal Information in our possession to a successor entity in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and you affirmatively opt-in to accept it. Personal Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor entity.

vi.  Marketing Communications

We will email you about products and services that we believe may be of interest to you. If you wish to opt-out of receiving marketing materials from us, please send us a message at marketing@browz.com. You may also choose to unsubscribe from our emails by following the instructions at the bottom of each email for opting out.

B.    Choice 

Users located in the EEA may direct us not to disclose their Personal Information to third parties (other than our service providers). We do not use Personal Information for purposes materially different from the purposes for which we originally collected the information without notifying the relevant individuals of such uses and offering an opportunity to opt out.

Notwithstanding the foregoing, we may disclose Personal Information without offering individuals the opportunity to opt out for the reasons described in more detail in Sections 5(A)(iv) (“By Law, to Protect Rights and to Comply with Our Policies”) and 5(A)(v) (“Business Transfers; Bankruptcy”) above.

C.   Non-Personal Information

From time to time, we may also release the Non–Personal Information gathered from BROWZ Services users in the aggregate, such as by publishing a report on trends in the usage of the BROWZ Services.

6.   Security

We maintain reasonable and appropriate administrative, technical, organizational and physical safeguards designed to protect and secure your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that we cannot guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

7.   Accessing and Modifying Account Information

Upon request, we will grant individuals reasonable access to Personal Information that we hold about them for the purpose of verifying the accuracy of correcting, amending, or deleting such Personal Information where it is inaccurate or if it has been processed contrary to the Privacy Shield Principles.

We reserve the right to deny access or limit access in cases where the burden or cost of providing access would be disproportionate to the risks to your privacy, in the case of a fraudulent request or requests intended to harass or annoy; where the rights of another person would be violated; or if full access would reveal our own confidential commercial information, such as marketing inferences, classifications generated by us or the confidential commercial information of another that is subject to a contractual obligation of confidentiality.

We may further restrict access to Personal Information for the following reasons:

A. Interference with the execution or enforcement of the law or with private causes of action, including the prevention, investigation or detection of offenses or the right to a fair trial;

B. Disclosure where the legitimate rights or important interests of others would be violated;

C. Breaching a legal or other professional privilege or obligation;

D. Prejudicing employee security investigations or grievance proceedings or in connection with employee succession planning and corporate re-organizations;

E. Prejudicing the confidentiality necessary in monitoring, inspection or regulatory functions connected with sound management, or in future or ongoing negotiations involving the organization;

F. Countervailing public interests; or

G. Requests purely for research or statistical purposes.

We may charge fees when justified, such as for access requests that are manifestly excessive, in particular because of the repetitive character.

BROWZ Services users may update Personal Information that is stored in their BROWZ Services user account by visiting the Settings page in the BROWZ Services. BROWZ Services uses may update their Personal Information by contacting our data privacy office at the address provided in Section 13 (“How to Contact Us”) below.

8.   Children

The BROWZ Services are not intended for children under 18 years of age. We do not knowingly collect Personal Information from children under the age of 18. If you are under 18, please do not give us any Personal Information. If you have reason to believe that a child under the age of 18 has provided Personal Information or any other information or content to us, please email us at dataprivacy@browz.com, and we will endeavor to delete it from our databases. Please be advised, however, that the removal of such materials from our databases does not ensure complete or comprehensive removal of such materials from the BROWZ Services.

9.   Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. Because of changes in technology and the growth and development of our business, or for other business reasons, we may need to change this Privacy Policy from time to time. We will alert you via the BROWZ Services the first time you log in after the Privacy Policy is modified, and we will post a copy of the new policy with its effective date on the BROWZ Services. It is therefore important that you notify us if you change your email address. If you do not provide us with a current email address, you should regularly review this policy to ensure that you are informed of any changes.

10.  Online Tracking

We currently do not process or comply with any web browser’s “do not track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who use our services.

11.   Collection and Use of Information by Third Parties

A.   General

      The BROWZ Services may contain links to third party sites. We do not control or endorse such third party sites, and we are not responsible for the privacy practices of such sites. Third parties are under no obligation to comply with this Privacy Policy with respect to Personal Information that you provide directly to those third parties or that those third parties collect for themselves. This Privacy Policy does not apply to information provided to third-party sites or gathered by the third parties that operate them. Before visiting a third-party site, whether by means of a link on our BROWZ Services or otherwise, and before providing any Personal Information to any third party, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that site, and should take those steps necessary to your discretion, to protect your privacy.

B.   Third Party Collection of Information for Analytics Purposes

We may use third party companies (currently including Google and Pardot) to provide us with analytics information. These companies may collect Personal Information and Non-Personal Information from you via our BROWZ Services. You can find out more information about what information Google and Pardot collect and how they use and disclose that information here: http://www.google.com/policies/privacy/;
http://www.pardot.com/company/legal/privacy-policy/.

C.   Google Maps

We allow you to determine how far away suppliers are located via Google Maps. If you select this functionality, you will be directed to Google Maps. You can find out more information about what information Google collects and how they use and disclose that information here: http://www.google.com/policies/privacy/.

12. Enforcement

A.  Unauthorized Disclosure of Information

If we become aware that the security of any of the BROWZ Services has been compromised or your Personal Information has been disclosed to unrelated third parties as a result of external activity, including but not limited to security attacks or fraud, we reserve the right to take reasonable and appropriate measures, including but not limited to, investigation and reporting, and notification to and cooperation with law enforcement authorities.

If we become aware that your Personal Information has been disclosed in a manner not permitted by this Privacy Policy, we will make reasonable efforts to notify you, as soon as reasonably possible and as permitted by law, of what Personal Information has been disclosed, to the extent that we know this information.

B.   Complaints – EEA Users

If you are located in the EEA and have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.  Filing a complaint in English will expedite the process. The filing of a complaint and the subsequent dispute resolution process are at no cost to you.  We will respond to complaints within 45 days of receipt of the complaint, and we will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Privacy Policy, unless the complaint is obviously unfounded or frivolous.  For users located in the EEA, complaints that cannot be resolved between us are subject to the arbitration option established by the Privacy Shield Principles.  For information about dispute resolution under the Privacy Shield Principles go to www.privacyshield.gov . 

C.  Complaints – Non-EEA Users

Individuals who wish to file a complaint or who take issue with our EU Safe Harbor policies should direct such communication to our Chief Privacy Officer via e-mail or written communication at the address provided in Section 13 below. Our Chief Privacy Officer will explain the process to be followed when filing a complaint. Filing a complaint in English will expedite the process. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Privacy Policy. For complaints that cannot be resolved between us, in the United States of America we have agreed to participate in the dispute resolution via the United States Council for International Business.  For users located in certain other countries outside of the United States of America, complaints that cannot be resolved between us may be subject to resolution by a different body (remedies can include deletion, modification or correction of the Personal Information at issue). 

In the United States of America, we are also subject to the jurisdiction of the US Federal Trade Commission. The Federal Trade Commission may be contacted at the following address:

Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580
consumerline@ftc.gov
www.ftc.gov

13.   How to Contact Us

If you have questions about this Privacy Policy, please contact us at:

Director of Information Security and Infrastructure
Privacy Shield
BROWZ, LLC.
13937 S. Sprague Lane
Suite 100
Draper, UT 84020
Email: dataprivacy@browz.com

Schedule 1 : Country Annexes
Annex A : Canada

2. Important Information for Non-U.S. Residents

If you are located outside of the United States, please be aware that any information you provide to us may be transferred to the United States of America, where it will be subject to the laws of that jurisdiction. By providing us with any personal information, you consent to this transfer.

3. Information We Collect

We collect both Non-Personal Information and Personal Information from you. “Non–Personal Information” is information that cannot reasonably be associated with an identifiable individual. “Personal Information,” by contrast, is information such as a name or email address that, can identify a specific individual.

4. How We Use Your Information

A. Personal Information

We will use your Personal Information for any purpose related to our business, including without limitation the following: (i) to respond to your requests and to provide you with the BROWZ Services and related services; (ii) to respond to your inquiries and contact you about changes to the BROWZ Services; (iii) as permitted by law, to send you notices (for example, in the form of e-mails, mailings, and the like) regarding products or services you are receiving; (iv) for billing and collection purposes; (v) to improve the BROWZ Services; (vi) as permitted by law, to contact you regarding other products or services we offer; (vii) for any other purposes disclosed at the time the information is collected or to which you consent; (viii) to carry out our obligations and to enforce our rights arising from any or all contracts entered into between you and us; or (ix) as otherwise specifically described in this Privacy Policy.

B. Non-Personal Information.

We analyze Non–Personal Information gathered from BROWZ Services users to help us better understand how the BROWZ Services is being used. By identifying patterns and trends in usage, we are able to better design the BROWZ Services to improve your experiences, both in terms of content and ease of use. We may apply Non-Personal Information respecting companies and employers, including predictive scores, to Personal Information of individuals associated with those firms. Automatic data collection may be performed on our behalf by our services providers.

5. How We Disclose Your Information/Onward Transfer

A.  Personal Information

i. Employees, Third-Party Processors and Third-Party Service Providers.

We will disclose Personal Information to our contractors, affiliates, distributors, dealers, vendors and suppliers who process Personal Information on our behalf, participate with us in the provision or operation of the BROWZ Services, or provide you with services. We require service providers to whom we disclose Personal Information and who are not subject to laws based on the European Union Data Protection Directive to contractually agree to provide at least the same level of protection for Personal Information as we provide ourselves. More particularly, third-party processors and service providers are bound contractually to use Personal Information only for the purposes for which it was provided to keep it confidential, to refrain from transferring it to other parties and to protect it with appropriate security safeguards. When the services they render to us have been completed or our arrangement with them is terminated, processors and service providers are required to return to us any Personal Information they have received, or to securely destroy it.

ii. Business Transfers; Bankruptcy

If we are a party to a prospective business transaction, we may transfer Personal Information to other parties to the transaction in order to determine whether to proceed with the transaction, binding such parties contractually to use and disclose the Personal Information in question solely for the purposes for which it was provided, to protect it by appropriate security safeguards, and if the transaction does not proceed, to return the information in question to us or securely destroy it.

We reserve the right to transfer all Personal Information in our possession to a successor entity in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and you affirmatively opt-in to accept it. Personal Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor entity.

iii. Marketing Communications.

As permitted by Canada’s Anti-Spam Law, we will email you about products and services that we believe may be of interest to you. If you wish to opt-out of receiving marketing materials from us, please send us a message at marketing@browz.com. You may also choose to unsubscribe from our emails by following the instructions at the bottom of each email for opting out.

Schedule 1 : Country Annexes

Annex B : United Kingdom

Unless otherwise provided for in this Schedule 1, Annex C, the Global Privacy Policy shall apply. In the Global Privacy Policy, Sections 3, 4. A., 4, C., 4. D., 5. A. iii., 5. A. vi., 7 shall be replaced in their entirety with the following sections:

1. Information We Collect.

We collect both Personal Information and Non-Personal Information from you. “Personal Information” is details about personal or factual conditions of a specific or identifiable individual person, such as a name, function, address, or email address. All other information is “Non–Personal Information”.

2. How we use your information

Where BROWZ proposes using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed above.

3. How we disclose your information/Onward Transfer

We may disclosure your personal information to certain third parties (“Data Processors”) that BROWZ uses to process your information on our behalf, for example to host our information technology infrastructure or to carry out data analysis. BROWZ requires Data Processors to enter into a legally binding contract with BROWZ that complies with the provisions set out in the Data Protection Act 1998 and to comply strictly with our instructions. Furthermore, BROWZ requires that our Data Processors do not use your personal information for their own business purposes, unless you have explicitly consented to the use of your personal information in this way.

4. Accessing and Modifying Account Information.

Under the Data Protection Act 1998 you have the right to request a copy of the personal information BROWZ holds about you and to have any inaccuracies corrected. This is called a Data Subject Access Request. We have a statutory right to charge you £10 for carrying out a Data Subject Access Request and are obliged by law to require you to prove your identity which will include, but may not be limited to, providing us with two documents that conclusively prove your identity. We will always comply with the Data Protection Act 1998 in order to supply, correct or delete personal information about you that we process. Please address requests and questions about this to dataprivacy@browz.com.

Schedule 1: Country Annexes

Annex C: Federal Republic of Germany 

Unless otherwise provided for in this Schedule 1, Annex C, the Global Privacy Policy shall apply. In the Global Privacy Policy, Sections 3, 4. A., 4, C., 4. D., 5. A. iii., 5. A. vi., 7 shall be replaced in their entirety with the following sections:

1. Information We Collect.

We collect both Personal Information and Non-Personal Information from you. “Personal Information” is details about personal or factual conditions of a specific or identifiable individual person, such as a name, function, address, or email address. All other information is “Non–Personal Information”.

2. How We Use Your Information.

A. Personal Information.

By accepting this privacy policy you expressly consent that we may use your Personal Information for any purpose related to providing our BROWZ Services to you, including without limitation the following:  (i) to respond to your requests and to provide you with the BROWZ Services and related services; (ii) to respond to your inquiries and contact you about changes to the BROWZ Services; (iii) to send you notices (for example, in the form of e-mails, mailings, and the like) regarding products or services you are receiving; (iv) for billing and collection purposes; (v) to improve the BROWZ Services; (vi) to contact you regarding other products or services we offer;  (vii) for any other purposes disclosed at the time the information is collected or to which you consent; (viii) to carry out our obligations and to enforce our rights arising from any or all contracts entered into between you and us; or (ix) as otherwise specifically described in this Privacy Policy.

Where BROWZ proposes using your Personal Information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for the use of your Personal Information for purposes other than those listed above.

B. Non-Personal Information.

We analyze Non–Personal Information gathered from BROWZ Services users to help us better understand how the BROWZ Services is being used.  By identifying patterns and trends in usage, we are able to better design the BROWZ Services to improve your experiences, both in terms of content and ease of use.  We may append Non-Personal Information, including predictive scores, to Personal Information, such as your address.  Automatic data collection may be performed on our behalf by our services providers.

C. How long will my personal information be kept for?

We will hold your Personal Information on our systems for as long as it is necessary (i) to provide you with the BROWZ Services and related services, (ii) for billing and collection purposes or (iii) to terminate the contract with you or as long as it is set out in any relevant contract you hold with us.

3. How We Disclose Your Information/Onward Transfer.

A. Personal Information.

i. Employees, Third-Party Processors and Third-Party Service Providers

We will disclose Personal Information to our contractors, affiliates, distributors, dealers, vendors and suppliers who process Personal Information on our behalf, participate with us in the provision or operation of the BROWZ Services, or provide you with services. We require service providers to whom we disclose Personal Information and who are not subject to laws based on the European Union Data Protection Directive to contractually agree to provide at least the same level of protection for Personal Information as we provide ourselves. More particularly, third-party processors and service providers are bound contractually to use Personal Information only for the purposes for which it was provided, to keep it confidential, to refrain from transferring it to other parties and to protect it with appropriate security safeguards.  When the services they render to us have been completed or our arrangement with them is terminated, processors and service providers are required to return to us any Personal Information they have received, or to securely destroy it.

Ii. Marketing Communications

By accepting this privacy policy you expressly consent that we may email you about products and services that we believe may be of interest to you.  If you wish later to opt-out of receiving marketing materials from us, please send us a message at marketing@browz.com.  You may also choose to unsubscribe from our emails by following the instructions at the bottom of each email for opting out.

4. Accessing and Modifying Account Information. User rights.

Upon request, we will grant individuals reasonable access to Personal Information that we hold about them for the purpose of correcting, amending, or deleting such Personal Information where it is inaccurate. The individuals’ rights of information and of correction, deletion or blocking of Personal Information according to the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) remain unaffected. In addition to the extent it is applicable and/or mandatory, we fully comply with all relevant provisions of the BDSG. 

BROWZ Services users may update Personal Information that is stored in their BROWZ Services user account by visiting the Settings page in the BROWZ Services.  

BROWZ Services users may address requests and questions with regard to their Personal Information or update their Personal Information by contacting our data privacy office at the address provided in Section 13 (How to Contact Us) above.