Last Modified: November 23, 2023

INTRODUCTION

Privacy is at the foundation of Bricktime LLC (“Brick”, “we”, “our”, or “us”). Our approach is simple: we only collect information that is absolutely necessary for functionality — no tracking

This Privacy Policy (“Policy”) describes our practices for collecting, using, maintaining, protecting, sharing and disclosing your information through joinbrick.com (our “Website”), our mobile application (our “App”) and our products, services, technology platforms and related applications (collectively, the “Service” or “Services”).

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our terms, your choice is not to use our Services. By accessing or using our Services, you agree to this Privacy Policy. This Policy may change from time to time (see CHANGES TO THIS POLICY). Your continued access of our Services after we make changes is deemed to be acceptance of those changes, so please check the Effective Date at the top of this Policy, to ensure that you are viewing the most current version of this Policy.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Personal Information: In the course of registering an account on our App and filling out a contact form on our Website, we collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”).

Personal Information we collect about you includes:

• Email Address

• User-Generated Data: You may have the ability to interact with parts of our Services, such as the ability to communicate with our AI-enabled Services or otherwise provide information on or through Brick (collectively, "User-Generated Data"). Please do not upload any Personal Information when submitting User-Generated Data. Your User-Generated Data may be accessed by or transmitted to third parties and are submitted at your own risk.

We do not collect this information without your consent.

You may use the App without registering an account, in which case we will not ask you for any personal information. However, you are required to register an account on our App if you choose to use across-device syncing functionality or AI-enabled Services. In order to register an account, we ask only for your e-mail address.

We and our privacy-first analytics provider, Fathom Analytics, may automatically collect anonymized traffic statistics on our website. This information cannot be linked to you or any individual, or used to track you across other websites. We do this to improve services we offer you, conduct analytics, and improve site functionality.

This also means we don’t use non-essential cookies and do not display a “cookie banner”. Essential cookies are used for the sole purpose of providing the Service and cannot be disabled.

When you provide us with information in connection with a particular activity or otherwise sign up for or order our products and Services or provide your contact information to us, including your email address in connection with that activity, product or service, you agree that such action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to receiving communications from Brick through the information you provided to us. For more information on how to access and control your communication preferences, please see YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION, below.

Third-Party Services

When you connect with us through a third-party platform we may receive some information from your third-party account, and what we collect depends on your privacy settings with that service.

If you choose to register an account in our App, authentication will be performed by logging into your account with a third-party service (“TPS”) such as Apple or Google via our App. In that case we will use the Personal Information you have provided to the TPS — your email address — to create your account. Note that the information we collect from and through a TPS may depend on the privacy settings you have set with the TPS and the permissions you grant to us in connection with linking your account with the Service to your account with a TPS. Other than what we may share with the TPS as described below, the Personal Information a TPS has about you is obtained by the TPS independent of our Service, and Brick is not responsible for it.

HOW WE USE YOUR INFORMATION

We may use information that we collect about you or that you provide to us, including any personal information:

• To deliver, provide, and process payment for the Services.

• To improve our Services.

• To address your inquiries.

• To tailor content we display to you and offer we may present to you, both on the Service and elsewhere online.

• To communicate, promote to you and send updates about products, services, offers, and events offered by Brick.

• To comply with legal requirements and assist law enforcement.

• To stop any activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or a legally actionable activity.

• To identify Brick users

• For the purposes disclosed at the time you provide your information, and 

• As otherwise permitted with your consent.

Legal Bases

To process your information as described above, we rely on the following legal basis:

• Contractual Necessity: To provide you with the Brick Service and perform the contract that you have with us. 

• Legitimate Interests: It is in our legitimate interests to improve and analyze our Service, promote our products, prevent fraudulent transactions, maintain security of our Services, and provide functionality.

Consent: In instances where we have indicated we will ask for consent within this Privacy Policy, you may withdraw your consent at any time by contacting us. Please see the HOW TO CONTACT US section for more information.

HOW WE DISCLOSE AND SHARE YOUR INFORMATION

We don’t sell your information to anyone.

We don’t share your information to any third-parties for marketing purposes.

We only share your information with our service providers for the sole purpose of providing the Services. We share information we receive about you as follows:

• With our service providers and network partners:

  • We employ third party companies and individuals to provide Services on our behalf, to perform Service-related operations (e.g., without limitation, maintenance services, database management, web analytics, server hosting, fraud detection and improvement of Brick’s features) or to assist us in providing and analyzing how our Service is used. For example, we use Framer to provide our website hosting and have partnered with third-party providers to rent our servers. We use ConvertKit and Loops as our email marketing providers.

  • If you choose to use our AI enabled features we will disclose user-generated data with our AI service provider for the purpose of performing Service-related operations (e.g., to generate responses or other requested outputs)

  • Brick uses OpenAI for all AI Services. For more information on how our service provider, OpenAI protects your Personal Information, please see their Privacy Policy.

  • Additionally, app stores, such as App Store or Google Play, host our App and process any in-App purchases that you may make, or subscriptions you sign up for. These third parties may have access to your Personal Information in order to perform these tasks on our behalf. 

• For corporate transactions:

  • Brick may share information, including Personal Information, with any current or future subsidiaries or affiliates, primarily for business and operational purposes. We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.

• When required by law:

  • Brick will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law.

  • We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect the property and rights of Brick or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify Brick Users and may do so in cooperation with third parties at our discretion.

• With your Consent:

  • You may submit Personal Information to us through a form on the Website and consent to receive communication from us based on the information in the form.

YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION

You can access, update, or delete your information by accessing your Account settings in the App or by emailing us at: help@joinbrick.com.

You also may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. 

Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications.

HOW WE RETAIN YOUR INFORMATION

Unless you request that we delete certain information (see YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION), we will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Website);

• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)

• Whether retention is advisable; and considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).

HOW WE SECURE YOUR INFORMATION

We only retain your information for the minimum length of time required to provide you with the Services or as otherwise required by law.

We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss. We restrict access to your personal information to those employees who need to know that information to service your account or perform their job functions.

Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure. Any transmission of your personal data is at your own risk and we expect that you will use appropriate security measures to protect your personal information.

You are responsible for maintaining the security of your account and the information in your account. We may suspend your use of all or part of the Services without Policy if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address on record on your account.

HOW TO CONTACT US

You can email us at help@joinbrick.com.

DO NOT TRACK SIGNAL

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. We do not track users and do not allow third-parties to track the personal information of our users on our Website.

CHILDREN’S PRIVACY

The Services are general audience and intended for users 13 and older. We do not knowingly collect Personal Information from anyone younger than age 13.

YOUR PRIVACY RIGHTS

Under the applicable privacy laws, Brick may be considered a “data controller”, “business”, or reasonably equivalent term.

If you are a resident of an applicable jurisdiction, you may have certain privacy rights with respect to our collection, use and disclosure of your Personal Information. Specific rights and how to exercise those rights are provided below::

• The right to know/access what Personal information we have collected and how we have used and disclosed that Personal Information. 

  • Please see the above section within this Policy titled INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT, to see the categories of Personal Information we have collected about you.

  • Please see the above sections within this Policy titled HOW WE USE YOUR INFORMATION and HOW WE DISCLOSE AND SHARE YOUR INFORMATION, to see applicable use and disclosures of your Personal Information.

• The right to request deletion/object to/restrict the processing of your Personal Information.

  • Please see the deletion account settings within the App or contact us at help@joinbrick.com.

• The right to the portability of your Personal Information.

  • Please contact us at help@joinbrick.com.

• The right to be free from discrimination related to the exercise of any of your privacy rights. 

  • You will not be discriminated against, and the quality of Services provided to you will not diminish due to your exercising any of your privacy rights.

• The right to opt out of the sale of your personal information, and to request information about whether we have sold your personal information in the past 12 months. 

  • Brick does not sell personal information, nor do we share personal information with third parties for marketing purposes, and we have not done so in the last year.

Please note that we may require you to verify your credentials, by matching your email address, or other account information to the information in our systems, before you can submit a request to exercise any of these rights. If you authorize another person to act as your agent to submit requests on your behalf, we will ask the agent to provide us the written and signed authorization that you provided to the agent, we will confirm with you that you did provide the authorization, and we will verify your identity.

Upon request, Brick will provide you with information about whether we hold any of your personal information. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you submit a request to access all personal information you’ve submitted, we will respond to your request to access within the time period required by applicable privacy laws.

We will use commercially reasonable efforts to honor your requests for deletion; however, certain residual information may actively persist on the Service even if you close your account. In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes). Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. It is not always possible to completely remove or delete information from our databases. If your information is deleted, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Services. 

Our Services require no or a minimum amount of Personal Information in order to function. Brick users who do not provide Personal Information (e.g., by not providing an email address) may not be able to access the full functionality of features found on Brick. 

For any questions related to your privacy rights, please contact help@joinbrick.com.

INTERNATIONAL JURISDICTIONS

Our servers are located in geographic areas, including the United States and Europe, and your personal information may pass through servers located in these geographic areas. If you are accessing the Services from another country, please be advised that you may be transferring your personal information to such geographic areas and countries and you consent to that transfer, processing and storage of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable US federal, state, and local laws concerning your use of the Services and your agreements with us. Any persons accessing our Services from any jurisdiction with laws or regulations governing the use of the Internet, including the collection, use, or disclosure of personal information, different from those of the jurisdictions mentioned above may only use the Services in a manner lawful in their jurisdiction. If your use of the Services would be unlawful in your jurisdiction, you may not use our Services.

CHANGES TO THIS POLICY

Brick may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are material changes to the way we treat your Personal Information, we will update the Last Modified date at the top of this Policy upon becoming effective. We may also notify you by email, in our discretion.