1. Introduction
1.1 eBrevia, Inc. (‘’we’’, ‘’us’’, ‘’our’’, “eBrevia”) is committed to safeguarding the privacy of our website visitors and service users. In this Privacy Notice (‘’Notice’’) we explain how we collect, share, use, and protect your personal data. By using this website, you are accepting and consenting to the practices described in this Privacy Notice.
1.2 This Notice was last updated January 11, 2024.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is consent or our legitimate interests namely monitoring and improving our website and services or a contract between you, your company or your employer and us.
2.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests namely monitoring and improving our website and services or a contract between you, your company or your employer and us.
2.4 We may process information contained in any inquiry you submit to us regarding products and/or services ("inquiry data"). The inquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent or our legitimate interests namely monitoring and improving our website and services or a contract between you, your company or your employer and us.
2.5 We may process your personal data that are provided in the course of the use of our services ("service data"). The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests namely monitoring and improving our website and services or a contract between you, your company or your employer and us.
2.6 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, operate and provide our services, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent or our legitimate interests namely monitoring and improving our website and services or a contract between you, your company or your employer and us.
2.7 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
eBrevia limits its collection and use of personal information to the minimum identifiers that are necessary for performing the specific task related to the purpose for which the personal information is collected.
3. Providing your personal data to others
We may have to share or disclose your personal data with entities and persons set out below and other relevant third parties for the purposes listed herein. We may share or disclose your personal information we collect about you with:
Our affiliates, group companies, vendors, consultants and other service providers to perform the services on our behalf and to ensure the efficient operation of our business.
Our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Payment services providers. We will share or disclose transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
Service providers who provide information technology and system administration services to us.
We may share or disclose your information in response to a request for information, if upon review we determine that disclosure is in accordance with, or required by, any applicable law, regulation or legal process.
We may share or disclose your personal information in connection with or during negotiations of any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.
We may also share or disclose your personal information if we determine that your actions are inconsistent with our user agreements or policies, or if we must protect the rights, property and safety of eBrevia or others in accordance with, or required by, any applicable law, regulation or legal process.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 eBrevia has business processes in operation across borders and cannot always limit the processing of personal information to the country in which an individual is based. Our offices are located in the United States. In the course of providing you services, eBrevia may need to transfer personal information to locations outside the jurisdiction in which it is provided or where our site is viewed. We comply with applicable legal requirements providing adequate safeguards for the transfer of personal information to countries other than the country where you are located.
4.3 The hosting facilities for our website are situated in North America, South America, Europe, Asia, and Australia. However, we host in the United States only unless instructed otherwise by you. Any data transfers between the U.S., European Union (EU), and other countries will only be done subject to compliance with applicable law and appropriate technical and organizational safeguards of such data. This includes onward transfers to third parties. eBrevia requires our third parties to implement the necessary safeguards to best protect personal information both in transit and at rest. In the event that such onward transfers are not conducted per our terms, we acknowledge that we may be liable for any resulting outcomes.
5. California Consumer Privacy Act Notice
5.1 This CCPA Notice, in conjunction with the other portions of this Notice, provides information for certain California residents in connection with the California Consumer Privacy Act of 2018 (“CCPA”). Under the CCPA, and for purposes of this CCPA Notice, “Personal Information” means information that identifies, relates to, or describes a California resident or household and includes the categories listed below. Below are details about the categories of Personal Information of California residents that we have collected or disclosed during the last 12 months. Personal Information does not include:
Publicly available information from government records.
Information excluded from the CCPA's scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (‘’HIPAA’’) and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (‘’FCRA’’), or the Gramm-Leach-Bliley Act (‘’GLBA’’).
De-identified or aggregated consumer information. De-identified information is data that has had all personally identified information removed from it. Aggregated information is numerical or non-numerical information that is compiled into data summaries or summary reports for data statistics or public reporting.
5.2 Information Collected. We collect the following categories of Personal Information:
Examples
Category
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Identifiers
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Commercial information.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Internet or other similar network activity.
Current or past job history or, performance evaluations.
Professional or employment-related information
We do not collect: protected classification characteristics under California or federal law, biometric information, geolocation data, sensory data, professional or employment related information, non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) or inferences drawn from other personal information. We will not collect additional categories of personal information without providing notice,
5.3 Sources of Personal Information. We collect Personal Information (a) directly from California residents themselves, as well as from other sources, such as public databases, your employer and its employees, our affiliates, third-party sources of demographic information, and social media platforms, or (b) indirectly from California residents, from observing your actions on our website.
5.4 Purposes. We use this Personal Information to:
operate, manage, and maintain our products and services,
to provide our products and services,
to communicate with our customers, prospective customers, suppliers, employees and other associated entities and persons, and to otherwise achieve our business purposes and objectives.
Our business purposes and objectives include:
developing, improving, supporting, servicing and maintaining our products, services, customer relationships and employee relationships;
personalizing, advertising, and marketing our products and services;
conducting research and data analysis;
maintaining our facilities and infrastructure;
undertaking quality and safety assurance measures;
conducting risk and security controls and monitoring;
detecting and preventing fraud;
performing identity verification;
performing accounting, audit, and other internal functions, such as internal investigations;
complying with laws, regulations, and internal policies (including responding to requests from California residents under the CCPA);
maintaining records; and exercising rights and defending legal claims.
We will not use the personal information we collected for materially different, unrelated, or incompatible purposes without providing notice.
5.5 Disclosures of Personal Information. We may share or disclose the categories of Personal Information listed above to our affiliates and relevant third parties, such as our service providers, consultants or professional advisors, or for our legitimate business purposes.
5.6 Sale of Personal Information. We do not “sell” Personal Information for purposes of the CCPA.
5.7 For purposes of this CCPA Notice, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
5.8 If you are a California resident, you may have the following rights:
● Right to Know. You have the right to request that we disclose to you the following information covering the 12 months preceding your request:
The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
The specific pieces of Personal Information we collected about you;
The business or commercial purpose for collecting Personal Information about you; and
The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information.
● Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you. Please note that eBrevia is not required to delete personal information if it is still needed in order to complete the transaction for which the information was collected, provide a good or service requested by you (or that we reasonably anticipate based on our relationship with you), perform a contract with you, comply with legal obligations, or accomplish any other objective recognized as an exception to the right to deletion under CCPA.
5.9 To make a request for the disclosures or deletion described above, please contact us at support@ebrevia.com. We will respond to your request consistent with applicable law.
5.10 Right to Be Free from Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information under the CCPA.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes unless as set forth below.
6.3 Personal data will be deleted from our live services at your request. Personal data on our backup servers will be retained for six (6) months following the termination of your license with us, at the end of which period it will be deleted from our systems.
6.4 Personal data will be retained for perpetuity only with the express written consent and permission of the client.
6.5 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, the period of retention of personal data will be determined based on the length of your license plus any renewal periods determined by you.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Security of personal data
7.1 We take appropriate technical and organizational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2 We will store all your personal data on secure servers, personal computers and mobile devices.
7.3 The following personal data will be stored by us in encrypted form: your name, contact information, IP address and password(s).
7.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
7.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
8. Amendments
8.1 We may update this Notice from time to time by publishing a new version on our website.
8.2 Please check this page frequently. Your continued use of our sites constitutes acceptance of such changes in this Notice, except where further steps are required by applicable law.
9. Your rights
9.1 In this Section 9, we have summarized the rights that you may have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
9.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, however additional copies may be subject to a reasonable fee.
9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. Please let us know if the personal information that we hold about you needs to be corrected or updated.
9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
9.8 To the extent that the legal basis for our processing of your personal data is:
(a consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
9.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
9.10 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.11 You may exercise any of your rights in relation to your personal data by written notice to us. We will make reasonable efforts to comply with such requests, unless such requests are prohibited by law, or there is a legitimate business purpose to retain personal information. We reserve the right to verify your identity before any request to update or delete your personal information is processed by us. Please direct any questions about your personal information to eBrevia’s privacy team at support@ebrevia.com.
10. About cookies
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
11. Cookies that we use
11.1 We use cookies for the following purposes:
(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website;
(b) status - we use cookies to help us to determine if you are logged into our website;
(c) personalization - we use cookies to store information about your preferences and to personalize the website for you;
(d) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally; and
(e) analysis - we use cookies to help us to analyze the use and performance of our website and services.
12. Cookies used by our service providers
12.1 Our service providers other than Google Analytics do not use cookies.
12.2 We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.
13. Managing cookies
13.1 If you block cookies, you will not be able to log into our website.
14. Personal Data of children
We do not knowingly provide services or sell products to children. If you are below the age of 16, you may use our website only with the permission and active involvement of a parent or legal guardian. If you are a minor, please do not provide us or other website visitors with any personal information and do not use this website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.
15. Our details
15.1 This website is owned and operated by eBrevia, Inc.
15.2 We are incorporated in Delaware with our principal place of business located at 1800 Le Jeune Road, Coral Gables, FL 33134 USA.
15.3 If you have any questions regarding eBrevia’s privacy practices, the use of your personal data, or about this Notice, please contact us at:
(a) by post, using at eBrevia, Inc., 1800 Le Jeune Road, Coral Gables, FL 33134 USA;
(b) by telephone, on (203) 870-3000; or
(c) by email, using support@ebrevia.com.
16. GDPR compliance
16.1 For questions pertaining to eBrevia’s GDPR policy, our GDPR compliance team's contact details are c/o Ethan O’Reilly, email: EOReilly@eBrevia.com.