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Privacy Policy Effective date: July 13, 2013
PRIVACY POLICYLast modified: 2018.
Your privacy is important for BRW and an essence to our service. This Privacy Policy explains what information we collect about you and why, what we do with that information, and how we handle that information
At BRW, we care about the confidentiality and privacy of your data and are fully committed to protecting it. This is something that will never change. BRW is not in the business of selling or renting your information. BRW shall not sell your personal data to third parties and shall only share it when necessary for the rendering of the BRW service as stated below.
1. IntroductionThis Privacy Policy establishes the conditions for the processing of personal data of users (the “User” or “you”) of the BRW Email Tracking Tech service (the “Service”) by BRW Enterprise, S.L. (“BRW” or “we”) as well as the conditions for the processing of personal data by BRW on behalf of Users within the Service.
BRW shall process personal data in accordance with European Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and applicable data protection laws.
2. Processing of personal data of Users by BRW (as Controller)2.1. This Section explains the processing of personal data of Users by BRW as a controller, that is, when BRW decides about the purposes and means for the processing of the data. This only happens regarding the data of the User used by BRW to render the Service (having an account). This does not include the communications sent by the User through the Service and related-data, which shall only be processed in accordance with Section 3 below.
BRW shall process as controller your personal data to provide you with the Service and to manage and improve the Service, including sending of communications regarding the Service or with information about the Service or BRW.
2.2. Personal data of Users processed by BRW for the above purposes may include contact information, such as name or email address, language preferences  and other personal data provided by the User in the context of the provision of the Service.
2.3. The legal basis for the processing of personal data of Users is the contractual relationship between the Users and BRW for the Service and also the legitimate interest of BRW of informing registered Users about the Service and the company, unless they opt out to receive this information .
2.4. Personal data of the Users will be processed by BRW throughout the term of the contractual relationship for the Service and subsequently for the period during which applicable regulations require such personal data be he held thereafter.
2.5. BRW may share the personal data with third parties, only for the provision of the Service and at all times subject to the guarantees and requirements provided by applicable data protection laws.
2.6. The User may at all times exercise his rights to access, rectification, erasure and restriction of processing and data portability as provided in the GPDR and applicable regulations by contacting BRW at 211 east 43rd st NY NY 10017; or, by sending an email to help@brwenterprise.com. 
If at any time the User wishes to stop receiving communications regarding BRW or with commercial information about the Service, the User may request so by sending an email to privacy@BRWenterprise.com
3. Processing of personal data on behalf of Users by BRW  (as Data Processor)3.1. This Section explains the processing of personal data by BRW on behalf of Users, as a data processor, that is, when the purposes and means for the processing of the data are decided by the User and BRW  only access the data for the rendering of the Service and on behalf of the User.
The Service may imply the access and processing by BRW of personal data controlled by the User and generated within the Service in relation to each electronic mail sent by the User through the Service (“Accessed Data”). In such cases, BRW  shall be deemed as the data processor and shall process such personal data only on behalf of the User and not for its own purposes.
The Accessed Data shall comprise:
  • Information required to identify the electronic mails sent through the Service:
    • information of the recipients;
    • subject of the email; and
    • date and time in which the email was sent; and
  • Information provided by the Service:
    • receipt confirmation;
    • open confirmation;
    • timestamp of each email opening;
    • history of the times (number, date and time) the recipient has opened the received email;
    • browser and operating system used by the recipient who opened the email;
    • number of links included in the email;
    • text and URL of such links;
    • timestamp of each click on the link; and
Accessed Data is the only information to which BRW shall access to provide the Service. Authorizations for Gmail and the connection to your Google account are needed technically for the rendering of the Service by BRW and to provide the email tracking service, but do not imply the access by BRW to any data or information of the User other than the Accessed Data. For your better understanding, this is the detail of the use of the above permissions by BRW:
  • Basic permissions: view your email metadata such as labels and headers, but not the email body. The Service needs this permission to identify your emails and correctly assign the open status (Green Check Marks).
  • Insert email into your inbox: this permission is necessary to add email alerts in your Gmail inbox when your emails are opened.
  • View and manage your basic email settings: The Service needs to know your settings (e.gl alias, design style) to work properly.
  • Manage mailbox labels: the check marks in mobile devices are added as labels. The Service needs this permission to add labels (check-marks) to your emails and update them when your emails are opened.
  • Read, send, delete and manage your email: The Service needs to delete the tracking pixel from your sent emails, so when you open your own emails you do not produce a self-open. The Service does not use the “ read” nor the “send” permissions, but unfortunately those permissions can not be removed separately. No one at BRW will read your emails, BRW will never send emails on your behalf and will never share the content of your emails.
  • Read and change your data in a number of websites (All usergooglecontent.com sites, All BRWenterpise.com sites, Inbox.google.com, mail.google.com). The Service modifies Gmail and Google Inbox websites in order to display the green check marks as well as the BRW website.
As detailed in the above permissions, some of them are never used by BRW, but the permission system from Google does not have enough granularity to select only the ones that BRW really needs.
BRW guarantees that:
  • Only automated software uses the above permissions
  • No one at BRW reads your emails
  • BRW will never send emails on your behalf
  • BRW will never share the content of your emails with third parties
  • BRW will never share your browsing data with third parties
  • BRW doesn’t store the body of your emails.
3.2. Accordingly, BRW shall:
(i) not process the Accessed Data for a purpose other than the provision of the Service requested by the User and shall not transfer such data, not even for their storage, to unauthorized parties;
(ii) process the Accessed Data only on documented instructions from the User; and if BRW is aware that or of the opinion that any instruction given by the User breaches the data protection regulations, BRW shall immediately inform the User;
(iii) notify the User promptly if it becomes aware of any data breach and shall provide full details of the relevant breach;
(iv) ensure that persons authorized to process the Accessed Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
(v) taking into account the nature of the processing, assist the User by appropriate technical and organizational measures, insofar as this is possible, for the fulfilment of the Users’ obligation to respond to requests for exercising the data subject’s rights laid down in Chapter III of the GDPR;
(vi) take all measures required pursuant to Article 32 of the GDPR (Security of Processing);
(vii) assist the User in complying with its obligations pursuant to Articles 32 to 36 of GDPR taking into account the nature of processing and the information available to BRW, including but not limited to, assisting the User with:
(viii) at the choice of the User, delete or return all the Accessed Data to the User after the end of the provision of Service, unless the storing of the data is required by applicable law; and
(ix) make available to the User all information necessary to demonstrate compliance with the obligations laid down in Article 28 of GDPR and allow for and contribute to audits, including inspections, conducted by the User or another auditor mandated by the User.
3.3 BRW shall not subcontract third parties for the processing operations which may imply access to the Accessed Data without the authorization of the User.
In this respect, the following sub-processors are deemed as authorized by the User:
  • Amazon Web Services, Inc. and GoDaddy as provider of the hosting of the Service, through servers located in the United States.
  • Google services: Google Apps, Google Analytics, Webmaster Tools and Google Forms
  • LogEntries for server logs storage
3.4. BRW shall guarantee the confidentiality of the Accessed Data, even after the termination of the Service.
3.5. The User is the data controller of the processing of the Accessed Data within the meaning in GDPR. The User is the only one deciding the purposes and means for the processing of Accessed Data, so BRW does not use Accessed Data for its own purposes and only uses them for the rendering of the Service and on behalf of the User. To such extent, the User shall have to comply with applicable obligations under data protection regulations, including relying on an appropriate legal basis for the processing of personal data of the recipients of the emails sent through the Service. The User, and not BRW, shall be solely responsible for the compliance with such obligations.
3.6. The User acknowledges and agrees that the use of the Service and the processing of the Accessed Data as a result of the same is its own free and exclusive decision and has verified that the conditions of the Service and the processing of the Accessed Data are in line with its interests.
4. SecurityBRW shall process all personal data in the strictest confidentiality and implement the appropriate technical and organisational measures as required by applicable regulations.
We use industry-standard encryption to protect your data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology.
5. Exclusion of BRW service5.1. The recipient of an email sent by the User of the Service may be excluded of the monitoring conducted by the User if the recipient selects the checkbox “Opt-out” section.
5.2. Due to technical limitations, the only way to exclude the recipient of the Service from the Service implies the installing of a cookie from the website BRW. Therefore, in case the recipient proceeds to delete cookies from his browser, the recipient will be included once again in the Service.
5.3. The aforementioned cookie will only work on the browser used by the recipient to select the exclusion. Therefore, in the event of using a different browser, the recipient will have to carry out the exclusion process on such browser.
6. Frequently asked questions about privacy6.1. How can I remove BRW access to my Google account and emails?
You can stop BRW access to your Google account by uninstalling the add on from your chrome browser. Just right click the icon with a briefcase and spyglass and click "remove from chrome". In such a case, you will not enjoy the Service any more.
6.2. Does BRW sell or rent my personal data or the content of my emails?
No, BRW does not sell or rent your personal data.
6.3. Do you need a data privacy agreement?
This Privacy Policy constitutes a binding data processing agreement (DPA) in case you need it.
6.4. Where is my information stored?
Information submitted to BRW will be transferred to, processed, and stored in Amazon.com services facilities and/or Godaddy.
6.5. How can I delete my personal data from the Service?
You can remove your Personal Data from the Service at any time by uninstalling the application from your chrome browser.
6.6 Does BRW store the body of my emails?
No, BRW doesn’t store the body of your emails.
6.7 Why does BRW need permissions to access your Gmail / Google Account and how those permissions are used?
This is the detail of the use of the permissions by BRW:
  • Basic permissions: view your email metadata such as labels and headers, but not the email body. The Service needs this permission to identify your emails and correctly assign the open status (green check marks).
  • Insert email into your inbox: this permission is necessary to add email alerts in your Gmail inbox when your emails are opened.
  • View and manage your basic email settings: The Service needs to know your settings (e.gl alias, design style) to work properly.
  • Manage mailbox labels: the green check marks in mobile devices are added as labels. The Service needs this permission to add labels (check-marks) to your emails and update them when your emails are opened.
  • Read, send, delete and manage your email: The Service needs to delete the tracking pixel from your sent emails, so when you open your own emails you do not produce a self-open. The Service does not use the “ read” nor the “send” permissions, but unfortunately those permissions can not be removed separately. No one at BRW will read your emails, BRW will never send emails on your behalf and will never share the content of your emails.
  • Read and change your data in a number of websites (All usergooglecontent.com sites, BRW sites, Inbox.google.com, mail.google.com). The Service modifies Gmail and Google Inbox websites in order to display the green check marks as well as the BRW website.
As detailed in the above permissions, some of them are never used by BRW, but the permission system from Google does not have enough granularity to select only the ones that BRW really needs.
6.8 Privacy code of conduct
BRW guarantees that:
  • Only automated software uses the above permissions
  • No one at BRW reads your emails
  • BRW will never send emails on your behalf
  • BRW will never share the content of your emails with third parties
  • BRW will never share your browsing data with third parties

​Additional Information:
BRW Enterprise ("us", "we", or "our") operates the www.brwenterprise.com website (the "Service").
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. 
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.brwenterprise.com
Information Collection And UseWe collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data CollectedPersonal DataWhile using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
  • Email address
  • First name and last name
  • Phone number
  • Cookies and Usage Data
Usage DataWe may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies DataWe use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
Use of DataBRW Enterprise uses the collected data for various purposes:
  • To provide and maintain the Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues
Transfer Of Data Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
BRW Enterprise will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure Of DataLegal RequirementsBRW Enterprise may disclose your Personal Data in the good faith belief that such action is necessary to:
  • To comply with a legal obligation
  • To protect and defend the rights or property of BRW Enterprise
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability
Security Of Data The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Service ProvidersWe may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
AnalyticsWe may use third-party Service Providers to monitor and analyze the use of our Service.
  • Google Analytics
    Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
    You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
    For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Links To Other SitesOur Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Children's PrivacyOur Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Changes To This Privacy PolicyWe may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us If you have any questions about this Privacy Policy, please contact us:
  • By email: info@brwenterprise.com
  • By phone number: 917.719.4482
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