Bright Spots Ventures LLC, A Massachusetts Limited Liability Company
Last Updated: December 10, 2024
For more detailed information, please click the links below to visit sections of our Privacy Policy:
What Information We Collect and How We Collect It
How We Use the Information We Collect
Legal Basis for Collecting and Using Information
With Whom We Disclose Information
Data Transfers and EU-US & Swiss-US Data Privacy Framework
“Do Not Track” and Global Privacy Control
Changes to this Privacy Policy
Introduction
This Privacy Policy covers how Bright Spots Ventures LLC, a Massachusetts Limited Liability Company (“Bright Spots Ventures,” “we,” or “our”) collects, uses, and discloses information about you (“personal information”) when you use our website or platform, submit registration for one of our events (both virtual and in-person events) or when you attend one of our in-person or virtual events, such as our Bright Spots in Healthcare Podcast. Learn more about Bright Spots in Healthcare here. This Privacy Policy also addresses any information collected from any acquired or assigned rights from our sponsors or partners.
For the purposes of this Privacy Policy, BSV is a Processor (provides services to its customers) when it gathers data from its customers to provide BSV’s services. BSV is a controller (i.e. the responsible party determining how data is to be used) for data gathered for its own purposes, including website visitors, marketing and ongoing communications.
For more information about the privacy practices of an BSV business customer, sponsor, or partner, please contact the respective business customer directly. We are not responsible for the privacy or data security practices of our business customers, sponsors, or partners, which may differ from those set forth in this Privacy Policy.
What Information We Collect and How We Collect
To provide our services to you and to ensure that our platform and events operate correctly, we collect various types of information, including personal information. When you use our website, sign up for our services, use our platform, or participate in any of our in-person or virtual events, we collect the following categories of information:
Information you provide to us:
- Identifiers and Contact Information. If you use the contact information provided on the BrightSpotsInHealthCare.com website to contact us directly, you agree to allow BSV to store and process your contact information. We will receive your contact information which may include, depending on how you contact us, your email address, name, company name, job title, the reason for contacting, and postal address.
- Customer Contact and Account Information. We receive and store the information you provide directly to us when you sign up for and use our services and platform. The types of information we may collect directly from our customers and users include name, email address, mailing address, phone number, job title, payment and billing information, and any other information provided by the user.
When you use our website or platform, we automatically collect the following information:
- Internet Protocol Address (“IP address”). IP addresses are assigned by your Internet service provider (e.g., Comcast/Xfinity, AT&T, Time Warner, Verizon, Charter, etc.) to the modem used to access the Internet for connected devices in your home and/or work-place. Any devices using the modem to access the Internet may broadcast the same IP address. At home, connected devices could include one or more laptop/desktop computers, tablets, mobile phones, smart/connected TVs and gaming consoles. At work, connected devices could include one (or all) floor(s) in an office building. Our website receives your IP address from your Internet browser each time you request a file or web page.
- User-Agent. Due to the nature of how the Internet works, we may receive information (known as “User-Agent”) automatically sent by your web browser, such as data associated with the source device’s Internet browser/content delivery software (e.g., Microsoft Explorer, Mozilla Firefox or Google Chrome). The User-Agent information we receive may also include information such as device type (e.g., computer, tablet, mobile device), and/or date/time of visit. Similar to the collection of IP addresses, our website also receives User-Agent information associated with your browser and type of device.
- Information collected by cookies and other similar technologies. We use various technologies to collect information which may include saving cookies to users’ computers. These tools help us understand and improve the performance of the BSV website and platform. Our cookie policy can be found here.
We do not collect sensitive personal information other than as may be necessary to collect payment, if payment is required, from our customers for our services. Unless we specifically request such sensitive information from you, we ask that you not send it to us or disclose any sensitive personal information to us.
Finally, we may also receive personal information about you from third parties, such as social networks, that help us identify prospective businesses or customers that might be interested in our products and services.
How We Use the Information We Collect
We use personal information for the following business purposes associated with our general business operations. We may collect your personal information for the following processing purposes:
- Services. We may use the personal information we collect in connection with the services we provide. We may use the personal information we collect to set up user accounts; provide, operate, and maintain services; process and complete transactions; provide customer service and support and respond to inquiries; send communications; prevent fraudulent activity; for any other purpose based on our legitimate interest.
- Website. We may use the personal information we collect to administer and improve the BSV website and platform.
- Promotional Communications. We may use your personal information to contact you with newsletters, marketing or promotional materials, and other information that may interest you. You may opt out of receiving any, or all, of these communications from us by following the instructions provided in any email we send or by following the unsubscribe link in those emails.
- Marketing. We may use the personal information we obtain from you, your interactions with us and our website, as well as from third parties who help us with our marketing efforts, to provide you with marketing and promotional content, to deliver targeted and relevant advertising and marketing to you, to determine the effectiveness of our marketing, prospecting and sales campaigns and to better understand our website visitors’ preferences. You can view and change your preferences concerning this use of information through your cookie settings or by submitting a data subject request to us.
- Analytics. We may use analytics information collected to understand general information and trends related to our website, such as how many users have visited our website during a given period of time and the types of devices the visitors use. The information is used by us to help improve consumers’ solutions.
- IP addresses – Fraud Prevention. Our use of IP addresses is limited to helping identify and combat potentially fraudulent activity. IP addresses are stored in our log files and are deleted after 30 days.
- Respond to Inquiries. If you choose to contact us directly (by email, form, or postal mail) using the contact information we provide on the BSV website, we will use your contact information to respond to your inquiry.
Legal Basis for Collecting and Using Information
If you are a user of the BSV website, we rely on several processing purposes, such as legitimate interest, as the legal basis for processing the personal data we collect via the website and platform. For instance, we may collect, process or disclose your personal information based on the following bases:
- As necessary to provide a service or perform a transaction (such as when we respond to your requests);
- Consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies);
- As necessary for legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Site); and
- Compliance with legal obligations, particularly in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws.
The provision of your personal data is partly a statutory requirement and partly a contractual obligation.
With Whom We Disclose Information
We may disclose information (including personal information) in the following instances:
- Vendors and Service Providers. We may disclose your information to vendors and service providers we engage to perform tasks on our behalf, for example, to help us deliver our services, bill our customers, and respond to support tickets. More details about these vendors and service providers can be found in our GDPR statement.
- Marketing. We may disclose your information to service providers and advertising networks as reasonably necessary for marketing our products and services.
- Affiliated Companies. We may disclose personal information with subsidiaries, affiliates, partners, or strategic partners as needed to provide our products and services and generally as necessary in the administration of a global organization.
- Corporate activity. If BSV is acquired or merged with another company, we will transfer the collected information to the acquiring company.
- Applicable order. Under certain circumstances, we may be required to disclose personal information if necessary to comply with a subpoena or court order, to establish or exercise our legal rights or defend against legal claims, or to cooperate with government and/or law enforcement officials.
- Other Disclosures With Your Consent. We may disclose your personal information with your consent to other unaffiliated third parties who are not described elsewhere in this Privacy Policy.
We may disclose de-identified information (i.e., information that cannot be used to identify an individual) for a variety of reasons, including under the following circumstances:
- To make our products better and foster transparency.
- If BSV is acquired or merged with another company, we will transfer aggregate information to the acquiring company.
- We may share de-identified information if necessary to comply with a subpoena or court order, to establish or exercise our legal rights or defend against legal claims, or to cooperate with government and/or law enforcement officials.
- For any lawful basis.
Cookies
The BSV website and platform may place cookies on your browser in order to identify you when you return to our website or log in to our software. You can also manage your privacy preferences with us anytime by clicking the cookie icon on our website. BSV’s cookie policy can be found HERE.
Security
We take security very seriously. BSV has implemented reasonable technical, administrative and organizational security controls designed to protect the confidentiality, integrity, availability and resilience of data. These measures include utilization of encryption technologies, creation and maintenance of policy overseeing the management of the security program, role-based access controls, password management, vulnerability management and secure software development protocols.
Data Retention
The time period for which we retain your personal information depends on the purpose for which we use your personal information and the applicable law for that type of personal information and use. BSV will keep your personal information for as long as you are using our services and platform or as long as we have a valid business purpose to do so and, thereafter, for no longer than is required or permitted by law.
Generally, information collected during your use of our website will be kept until you withdraw consent or your information is no longer needed for marketing or analytical purposes.
We will generally keep personal information collected by our platform or provided by customers for up to three months after the end of our business relationship and subject to our agreement with our customers. All payment information will be deleted three months after the processing unless we are required by law to keep it longer.
If you contact us directly using the contact information provided on the BSV website, we will generally retain your contact information for up to three months after we respond to your inquiry. After that, the communications will be deleted from our system unless we are required by law to retain them longer.
Data Transfers and EU-US & Swiss-US Data Privacy Framework
For visitor-facing components of BSV, all personal data are stored exclusively in Dublin, Ireland. Nevertheless, certain personal information may be stored or accessible outside of the European Economic Area, Switzerland, or the United Kingdom. For such transfers of personal information and/or where required by law, BSV relies on the Standard Contractual Clauses as a valid transfer mechanism.
BSV complies with the EU-U.S. Data Privacy Framework (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. BSV 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. BSV 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. BSV adheres to the DPF principles for onward transfers of personal data to third parties and remains liable for damages caused by third parties under the DPF. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit www.dataprivacyframework.gov/.
EU and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact BSV at:
Bright Spots Ventures LLC
14 Perry Henderson Drive, Suite 1416
Framingham, Massachusetts 01701
BSV has further committed to refer unresolved Data Privacy Framework complaints to JAMS, an alternative dispute resolution provider in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint.
If JAMS does not address your concern, you may be entitled to binding arbitration under the Data Privacy Framework Principles. For purposes of enforcing compliance with the Data Privacy Framework, BSV is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.
Children’s Privacy
The BSV website and platform were not developed or intended for individuals under the age of 18 and we do not knowingly collect information from children under the age of 18 years old. If you provide your information to us through a request form or any part of our platform you represent to us that you are at least 18 years old. If you learn that your child has provided us with personal information without your consent, you may alert us at hello@brightspotsinhealthcare.com and we will promptly take steps to delete such information.
“Do Not Track” and Global Privacy Control
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals.
Global Privacy Control is a browser setting that allows you to notify websites you visit about your privacy preferences. We honor website visitors’ Global Privacy Control signals.
Links to Other Websites
BSV’s website may, from time-to-time, contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with BSV. Linked websites may have their own privacy policies or notices, which we recommend you review if you visit those websites. This Privacy Policy only applies to personal information collected on this website. We have no control over third-party websites and are not responsible or liable for the content, privacy practices, or use of any websites that are not affiliated with BSV.
Your Rights
You may be able to exercise certain privacy rights. The rights available to you depend on our reason for processing your personal information and the requirements of applicable law (i.e., your rights will vary depending on whether you are located, for example, the European Union, the United Kingdom, Brazil, or California). Specifically, you may have the following rights:
- The right to confirmation on the existence of processing and to access the data: You may have the right to obtain from us confirmation as to whether personal information processed, and, where that is the case, to request access to the personal information. Depending on where you are located, you may also have the right to information about public and private entities with which the controller has disclosed personal data.
- The right to correct incomplete, inaccurate, or out-of-date data: You may have the right to request that we correct any personal information about you that is inaccurate. Depending on the purpose of the processing, you also have the right to request that we complete the personal information we hold about you where you believe it is incomplete, including by means of providing a supplementary statement.
- The right to the portability of data: You may have the right to request that we transfer the personal information we have collected about you to another organization, or directly to you, in a structured, commonly used, and machine-readable format, under certain conditions.
- The right to request anonymization, blocking, or deletion of personal information: You have the right to request the deletion of your personal information we have collected from you, subject to certain conditions and limitations under the law.
- The right to revoke consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time with future effect. Depending on where you are located, you may also have the right to request deletion of personal data that was processed based on your consent, or the right to know the consequences of revoking your consent. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
- The right to object to processing: You may have the right to object to our processing of your personal information, under certain conditions, and we can be required to no longer process your personal information. Such right to object may especially apply if we collect and process your personal information through automated decision making, such as profiling, to better understand your interests in our products and services or for direct marketing. If you have a right to object and you exercise this right, your personal information will no longer be processed by us for such purposes. Such a right to object may, in particular, not exist if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
- The right to opt-out of the sale or sharing of personal information: We do not sell your personal information in exchange for monetary consideration. In the event that we disclose your personal information to third parties for their marketing purposes, you may have the right to opt out of that disclosure. You may also have the right to request further information about the disclosure of your personal information for those third parties’ marketing purposes, such as the contact information of those parties, once per calendar year.
- The right to limit the use and disclosure of sensitive personal information: We will only use sensitive or special personal information as needed for the purposes for which it was collected or with your consent. We do not currently process sensitive personal information for purposes that may be limited under applicable law. If this changes, we will notify you, and you may have the right to restrict such additional uses.
- The right to non-discrimination for exercising a privacy right: We will not discriminate against you for exercising any rights.
- The right to obtain a list of third parties to which personal information was disclosed.
Exercising rights
To exercise any of your rights as set out above, please contact us by submitting a request at hello@brightspotsinhealthcare.com or by contacting us at Bright Spots Ventures LLC, 14 Perry Henderson Drive, Suite 1416, Framingham, Massachusetts 01701. Please note that you will need to verify your identity before we can fulfill your request. Your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will respond to your verifiable request within any prescribed timelines. In some regions, there may be limitations on how often a request relating to personal information may be submitted.
Appointing an authorized agent
You can designate an authorized agent to submit a request on your behalf. To do so, you will need to provide a written authorization or power of attorney signed by you for the agent to act on your behalf. You will still need to verify your identity with us.
Appeals
In some locations, you may be able to appeal any decision relating to a request to personal information. You can reach out to
balbert@sharedpurposeconnect.com if you have any questions.
Unsubscribe from marketing
You can opt out of receiving certain BSV marketing or promotional communications at any time by using the unsubscribe link in the email communications we send.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business.
Any changes we make to the Privacy Policy in the future will be posted on this page, so you should review it periodically.
If there are significant changes to our information practices, specifically how we process personal information, you will be provided with appropriate online notice. We will also post a notice on our home page if our Privacy Policy has changed.
How to Contact Us
If you have any questions about this Privacy Policy or its implementation, you may contact through BSV’s contact form, available at
www.brightspotsinhealthcare.com/contact/ or you can send correspondence to the following address:
Bright Spots Ventures LLC
14 Perry Henderson Drive, Suite 1416
Framingham, Massachusetts 01701
Cookie Policy
How We Use Cookies
We use cookies for a variety of reasons detailed below. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them in case they are used to provide a service that you use.
Disabling Cookies
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
The BSV Cookie Consent tool can be utilized to customize your cookie preferences. The tool will record when you have consented to our cookie policy and will ask for consent periodically to ensure users stay up-to-date with changes to our cookie and privacy policies. The consent tool specifically controls the marketing cookies and analytical cookies set by using the BSV website. Essential cookies cannot be disabled.
The Cookies We Set
If you create an account with us, then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out; however, in some cases they may remain afterwards to remember your site preferences when logged out.
Login related cookies
If we provide a login option, we will use cookies when you are logged in so that we can remember that you are logged in. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.
Email newsletters related cookies
If we offer newsletter or email subscription services, cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
Forms related cookies
When you submit data to us through a form such as those found on contact pages or comment forms, cookies may be set to remember your user details for future correspondence.
Essential cookies
Essential cookies and scripts are essential for our website to function. They allow visitors to move around our website and use its basic features, such as accessing secure areas of the website, opening navigation, and displaying content.
Analytics
Analytics allow us to count visits and traffic sources to the website, so that we can measure and improve the performance of our site. Analytics let us know which pages are the most and least popular and see how visitors move around the site. All of the information collected from analytics cookies is aggregated so it is anonymous.
Marketing
We use only a few third-party cookies. We may use Facebook, LinkedIn, and Google’s pixels to track our marketing efforts.
Personalization
These cookies and scripts allow us to remember choices you make (such as your user name and language) and provide enhanced, more personal features for you.
Cookies We May Use on the BSV website (www.brightspotsinhealthcare.com)
| Name | Provider | Cookie Classification | Purpose | Expiration |
|---|---|---|---|---|
_ga | Google Analytics | Analytics | Tracks website traffic and user interactions. | 2 years |
GDPR Statement
The General Data Protection Regulation (GDPR) is a European Union regulation which protects the rights of data subjects in the European Economic Area (EEA), with respect to the processing of their “personal data,” as such term is defined in the GDPR.
Table of Contents:
Compliance
What Personal Data is Collected and How it is Collected
How Long is Personal Data Retained
Children’s Privacy
Legal Basis for Processing
Controller and Processor
Subprocessors
International Data Transfers
Your Data Protection Rights Under GDPR
Direct Marketing
How to Contact Us
Changes to this GDPR Statement
Compliance
The BSV website and platform are designed to meet the principles of the GDPR. Here are some of the actions we’ve taken to ensure our compliance with GDPR:
- We limit the personal data we collect;
- We have established a legal basis for the processing of that data;
- We only retain personal data for a limited time period, after which, the data is deleted
What Personal Data is Collected and How it is Collected
Please see the BSV Privacy Policy, which describes the categories of information we process, the purposes for which we process personal data, and how we collect that personal data.
How Long is Personal Data Retained
We will keep personal information provided by customers for up to three months after the end of our business relationship and subject to our SaaS agreement. All payment information will be deleted three months after processing, unless we are required by law to keep it longer.
If you contact us directly using the contact information provided on the BSV website, we will retain your contact information for a period of up to three months after we respond to your inquiry. After that, the communications will be deleted from our system, unless we are required by law to retain it longer.
Children’s Privacy
The BSV website and platform were not developed or intended for individuals that are deemed to be children under applicable data protection or privacy laws, and we do not knowingly collect information from children.
Legal Basis for Processing
If you are a user of the BSV website or platform located in the European Economic Area, we rely on legitimate interest as the legal basis for processing the personal data we collect via the website and platform.
Controller and Processor
Depending on which features you choose to use, Bright Spots Ventures LLC, a Massachusetts Limited Liability Company, is both Controller and Processor of personal data covered by the Privacy Policy for purposes of European data protection legislation.
Subprocessors
In connection with the operation of our website, BSV may engage third parties (each a “Subprocessor”) to process your personal data. As a condition of permitting a Subprocessor to process your personal data, BSV will enter into a written agreement with each Subprocessor containing data protection obligations at least as protective as the technical and organizational measures BSV has put into place to protect your personal data from accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access.
We use the following Subprocessors to operate our website and provide our services:
| Name | Subprocessing Activity | Country of Origin |
|---|---|---|
| Amazon Web Services, Inc. | Cloud Service Provider | United States and Ireland |
| Analytics | United States | |
| SiteGround | Hosting | Bulgaria |
| Magnet Mail/Higher Logic | Store Customer Email Lists | United States |
International Data Transfers
If you are located within the EEA when you visit the BSV website or submit information to the BSV platform, we may transfer your personal data outside of the EEA. When we do, we will ensure that an adequate level of protection is provided for the information by using industry-standard encryption at rest and in transit.
Visit our Privacy Policy to learn more about the technical and operational measures we implement and our compliance with the EU-U.S. Data Privacy Framework and Swiss-U.S. Data Privacy Framework.
Your Data Protection Rights Under GDPR
If you are a resident of the European Union, you have certain data protection rights under the GDPR. BSV will take reasonable steps to allow you to access, review, update, rectify, or delete any personal data we hold about you.
In certain circumstances, you have the following data protection rights:
- Right of access. The right to obtain access to your personal data.
- Right to rectification. The right to erase or rectify inaccurate or incomplete data.
- Right to erasure. The right to obtain the erasure of your personal data in certain circumstances.
- Right to portability. The right to move, copy, or transfer personal data.
- Right to restrict processing. The right to restrict processing of personal data.
- Right to object to processing. The right to object to processing of personal data for certain purposes.
If you wish to exercise one of these rights, please contact us by using the contact details below. We may ask you to verify your identity before responding to these requests.
Direct Marketing
You may opt-out of receiving marketing communications at any time by unsubscribing from email marketing or by opting-out of any emails that we may send to you.
How to Contact Us
If you have any questions about this GDPR Statement, you may contact us online, or you may send correspondence to the following addresses:
USA Headquarters
Bright Spots Ventures LLC
14 Perry Henderson Drive, Suite 1416
Framingham, Massachusetts 01701
USA
Changes to this GDPR Statement
Please visit this page periodically to stay aware of any changes to this GDPR Statement, which we may update from time to time. If we modify this GDPR Statement, we will make the revised overview available at the URL of this page and indicate the date of the latest revision.