Privacy policy

DBK Ventures, Inc. dba Shanidar (“Company”) values your privacy and is committed to maintaining your trust.  The Company owns and manages the website located at https://brinkapp.co (the "Website"). We provide this Privacy Policy to inform you of our policies and procedures regarding the collection, use, and disclosure of personally identifiable information received from users of this Website, and all of the Company’s other products and/or services, including but not limited to, its mobile application (“App”), interactive features, widgets, and/or other online services that post a link to this Privacy Policy, and all content offered as a part thereof (the "Services").  

 

Mission

The Company’s mission is to make voting easy for everyone in the United States.  When you use our Website or App, you will know when to register, where you vote, who and what you're voting for -- everything you need to make election day a breeze.  With fully accessible tools and completely nonpartisan information, the Website and App can be your hub of information for voting.


We provide information regarding:


  1. Registration.  We will help you with questions such as what you need to register to vote in your state, how to register, and what happens if you moved since your last vote.  We'll give you everything you need to know to make sure your vote gets counted.

  2. Your Ballot.   We will help you with questions such as who you can vote for in this year’s election, what measures you are voting on in this election, and how these measures may affect you.  We provide links to campaign sites and local newspapers so that you can educate yourself regarding the issues.

  3. Your Vote.   On election day, our tools will find your nearest polling place, give you directions to get there, and let you know what you need to bring with you to vote.

  4. Ready for 2018.   Our election day guide explains how to make sure your right to vote is respected and you get a voice in your government.



 

General Data Protection Regulation

While the Company’s Website and App pertain to U.S.-based voting concerns and elections, and the Company does not advertise in the European Union (EU); the Company does not restrict visitors from the EU from visiting its Website or using its App.  As a result, the Company provides the foregoing information about how the Company processes your data, if you are an EU citizen.


The processing of Personal Information, such as the name, address, e-mail address, or telephone number of a data subject (“Personal Information” or “Personal Data”) that is voluntarily supplied by you, or supplied by an authorized third party, shall always be in line with the General Data Protection Regulation (“GDPR”), and in accordance with the country-specific data protection regulations applicable to the Company.  


By means of this Privacy Policy, our Company would like to inform the general public of the nature, scope, and purpose of the Personal Information we collect, use and process.  Specifically, European Union (EU) data subjects are informed, by means of this section of our Privacy Policy, of the rights to which they are entitled, and the recourse they may seek if they have any questions regarding the collection, use, and processing of their Personal Information by the Company.

Your Privacy Rights under the GDPR.   The GDPR includes the following rights for EU data subjects who provide their information to the Company in connection with the Services or visiting our Website:

  • The right to be informed about how we store, use, or share your data;

  • The right to access your data;

  • The right to rectify your data;

  • The right to have us erase your data;

  • The right to prevent us from processing your data;

  • The right to request copies of your data from us in a commonly-used and machine-readable format, free of charge, for the purposes of transfer to a third party, where technically feasible;

  • The right to object to use or sharing of your data; and

  • The right not to be subject to automated decision-making, including profiling.


Data Controller.   The Company is the “data controller,” as defined under the GDPR, or the legal entity which determines the purposes and means of the processing of Personal Information of the visitors to its Website and users of its App.  The Company is responsible for collecting your consent, managing consent-revoking, enabling right to access, etc. If you wish to revoke consent for us to store, use, or share your Personal Information, you may contact us at info@brinkapp.co.


Data Processor.   The Company is the “data processor," as defined under the GDPR, or the legal entity which processes your Personal Information.  The Company has not retained any third-party service provider to process your Personal Information. Any processing of Personal Information shall be done solely by the Company.  The Company maintains records of any processing activities it performs, and is able to show how the Company complies with data protection principles under the GDPR. It has effective policies and procedures in place.  If you have questions regarding the processing of your Personal Data, you may contact us at info@brinkapp.co.


Breach.   The Company has reasonable internal policies and procedures in place to effectively detect, report, and investigate a data breach.  The GDPR defines a Personal Information breach as “a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Information.”  The Company will notify you of a Personal Information breach where the Personal Information breaches are likely to present a risk to data subjects to data protection authorities (“DPAs”) without undue delay, and within 72 hours if feasible, after becoming aware of the breach; and communicate high-risk breaches to affected data subjects without undue delay.  The Company will provide you with: (i) contact details of the Data Protection Officer (DPO) or other contact person, (ii) a description of the nature of the breach, (iii) likely consequences of the breach, (iv) measures the organization has taken or proposes to take to address the breach, and (v) advice on steps data subjects can take to protect themselves.


Data Protection Officer.  The Company is not formally required to designate a Data Protection Officer (“DPO”) because it is not: (1) a public authority; (2) an organization that carries out regular and systematic monitoring of individuals on a large scale; or (3) an organization that carries out large scale processing of special categories of data, such as health information or information about criminal convictions.  Nonetheless, the Company voluntarily elects to appoint Dylan Bulkeley, President/CEO of the Company, as the DPO for this Company.  Mr. Bulkeley is responsible for data protection compliance and can answer any questions you may have about your Personal Information.  He may be reached at info@brinkapp.co.


Data Retention/Erasure.   We will retain your Personal Information for as long as needed to provide the applicable Services, or for a minimum period of four (4) years.  If, at any time after agreeing to this Privacy Policy, you: (1) change your mind about receiving information from us; (2) wish to revoke permission for us to retain and use your Personal Information; (3) wish to object to processing of your Personal Information; or (4)  wish for us to erase a copy of your data, please make a request to the Company at info@brinkapp.co.  If you request erasure of your data, we may retain some of your Personal Information only for legitimate business interests, such as fraud detection, prevention, and enhancing the safety of our Website; and to comply with our legal obligations, specifically our tax, legal reporting, and auditing obligations.


Our Response to Your Requests.   If you make any requests regarding your Personal Information, we will not charge you for compliance with the request.  The Company will respond and comply within one month. The Company reserves the right to refuse or charge for requests that are manifestly unfounded or excessive.  If we refuse your request, we will tell you why we are refusing your request.  You have the right to complain to the relevant supervisory authority and to a judicial remedy, but you must do so within one month of our refusal.


Complaints.  Without prejudice to any other administrative or judicial remedy, every EU data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement of the data subject considers that the processing of Personal Information relating to him or her infringes this Regulation.


Data Protection Impact Assessment (DPIA).   The Company is not required to undergo a DPIA because data processing is not likely to result in a high risk to data subjects, such as in cases where: (1) new technology is being deployed; (2) profiling operations may significantly affect individuals; or (3) processing is on a large scale and involves special categories of data.  None of those cases apply here.

Legitimate Business Interest under the GDPR.   Our use of your Personal Information is based on the legitimate business grounds that:

  • The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account – for example, in order to enable access to our Website on your device or charge you for our Services;

  • The use is necessary for compliance with a legal obligation;

  • The use is necessary in order to protect your vital interests or those of another person or entity;

  • We have a legitimate interest in using your information – for example, to provide and update our Website or Services, to improve our Website or Services so that we can offer you an even better user experience, to safeguard our Website or Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; and/or

  • You have given us your consent.

 

Use and sharing of personal information

This provision applies not only to EU data subjects, but to any person, including those residing in the U.S. or outside of the EU, who shares with us his, her, or a third-party’s Personal Information.  We may use and/or share your Personal Information:


  • To respond to your inquiries and your requests regarding our Services.

  • To send you information regarding our services and changes to our terms, conditions, and policies.

  • To complete your registration, and communicate with you regarding our Services.

  • To send you marketing communication and newsletters about our Services.  The Company likes to keep its clients, personnel and other interested parties informed of legal developments of interest to them.  If you do not wish to receive publications or details of events or seminars that we consider may be of interest to you, please let us know by emailing info@brinkapp.co.

  • To facilitate social sharing functionality.

  • To collaborate with business affiliates, partners, vendors, or service providers to provide you with our Services.

  • In connection with our business purposes and legitimate business interests, as described above, including but not limited to data analysis, audits, fraud monitoring and prevention, developing or enhancing new and existing products and/or services, expanding our business activities, etc.


We will not use and/or share your Personal Information:


  • With anyone except for our Company’s authorized service providers, business affiliates, and business partners, and strictly for business purposes; or unless we specifically inform you, and give you an opportunity to opt out of our sharing your Personal Information.  

  • To run interest-based advertising campaigns that collect Personal Information such as email addresses, telephone numbers, and credit card numbers.

  • To use or associate Personal Information with remarketing lists, cookies, data feeds, or other anonymous identifiers.

  • To use or associate targeting information, such as demographics or location, with any Personal Information collected from the ad or its landing page.

  • To share any Personal Information with Google or third party companies through our remarketing tag or any product data feeds which might be associated with our ads.

  • To send Google or third party companies precise location information without obtaining your consent.

However, we reserve the right to disclose Personal Information that we believe, in our sole discretion, to be necessary or appropriate in the following circumstances:

  • As required by law, such as to comply with a subpoena, or similar legal process.

  • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

  • To enforce our Terms and Conditions.

  • To allow us to pursue available remedies or limit the damage we may sustain. 

Collection of Other Information

Passively Collected Information:   Your visit to our Website may allow us to obtain certain additional, personally non-identifiable information that is collected passively using various technologies.  This information includes but is not limited to, for example, IP addresses, browser types, date and time of page views, location information associated with your IP address, domain names, your interactions to an ad delivered by us or our ad technology partners and other anonymous statistical data involving your use of the Website and/or our services.  This information cannot presently be used to specifically identify you.


Aggregated Personal Data:   The Company may analyze your Personal Information provided through the Website or in connection with rendering the Services, in aggregate form.   This aggregate information does not identify you personally. We may share this aggregate data with our partners, affiliates, agents, or service providers for business purposes.   We may also disclose aggregated statistics to explain our Services to current and prospective business partners, and to other third parties for other lawful, business-related purposes.

Website Tracking

We may, either directly or through third party companies and individuals we engage to provide services to us, also:

Track your use of our Website and the Services for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, etc.

  • Track your use of the Website and the Services to enable you to use and access the Services and pay for your activities on the Website and through the Services.  

  • Track your behavior on our own Website and use of the Services to market and advertise our services to you on our Website platform and third party websites.  You may opt out of receiving advertisements by visiting the Network Advertising Initiative (http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (http://www.aboutads.info/choices/).  Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on the Services, generally.  The advertising will simply not be targeted or specific to your interests.


Tracking Technologies on our Website/Cookies

When you visit our Website or otherwise interact with the Service, we may send one or more “cookies” to your computer or other devices.  Cookies are alphanumeric identifiers stored on your computer through your web browser and are used by most websites to help personalize your web experience.  Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third party websites.  Some features on this site will not function if you do not allow cookies. We may link the information we store in cookies to any Personal Information that you submit while visiting our Website.


We may use both session ID cookies and persistent cookies.  A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time.  Persistent cookies enable us to track and target the interest of our users to enhance the experience on our site.


Functional cookies, persistent and session type, store information to enable core site functionality, such as Live Chat and Client ID remembrance.


Analytics cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our site and our marketing campaigns.


Advertising cookies may be set through our Website by our advertising partners. Data may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to your interests.


If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.  


If you reject cookies, you may still use our site, but some features on the site will not function properly.


Children   


The Children’s Online Privacy Protection Act of 1998 (COPPA) and its accompanying FTC regulation protects the privacy of American children aged 13 and under, who are using the Internet.  The GDPR sets the age at which a EU child can give their own consent in order to process their Personal Data at 16 years of age.


The Website and our related Services are not intended for anyone under 16, and we do not knowingly collect information from anyone under the age of 16.  Anyone aged 16 or under should not submit any Personal Information without the permission of their parents or guardians. Parents or guardians may, on behalf of their children, submit their children’s Personal Information.  By using the Website and our related Services, you are representing that you are at least 16 years old and/or that you have the relevant legal authority to submit your Personal Information or that of a third-party minor, to the Company or on the Company’s Website.


Links to Other Websites   


From time to time, the Website and App may link to other websites such as, but not limited to Vote411.  Second, we may provide links for informational purposes to further information regarding various voting measures and candidate campaigns. Please note that the inclusion of a link does not imply any Company endorsement of the linked site, measure, candidate, etc. by us or by our affiliates.  If you visit the linked sites, please know that this Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third party websites or third parties who own or control those websites. This Privacy Policy applies only to this Website and the Company’s Services.


Security   


We maintain reasonable and appropriate, although not infallible, security precautions.  However, we cannot guarantee that hackers or unauthorized personnel will not gain access to your Personal Information, despite our reasonable efforts.  You should note that in using the Website, App, and/or our related Services, your information will travel through third-party infrastructures which are not under our control.  Please feel free to raise any questions, concerns or specific directions you may have regarding the privacy and security of your information to info@brinkapp.co.


Data Retention


We will retain your Personal Information for four (4) years, or as long as needed to provide the applicable Services.  Our data retention period may change in the future if a longer retention period is required or permitted by law.


Do Not Track   


Your browser setting may allow you to automatically transmit a "Do Not Track" signal to websites and online service you visit.  The Company’s Website does not respond to "Do Not Track" signals or other mechanisms from a visitor's browser. If, in the future, we create a program or protocol to respond to such web browser "Do Not Track" signals, we will inform you of the details of that protocol in this Privacy Policy.  To find out more about "Do Not Track," please visit https://www.allaboutdnt.com.


Advertising/Google AdWords


On this Website, the Company has integrated Google AdWords.


Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.


The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351.


The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.


If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.


The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.


The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, Personal Information, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These Personal Information are stored by Google in the United States of America. Google may pass these Personal Information collected through the technical procedure to third parties.


The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.


The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.


Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.


Analytics/Google Analytics


We and our third party tracking-utility partners use log files on our Service to automatically gather certain information, including but not limited to internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for analytics purposes.  Specifically, we analyze trends, administer the site, track users’ movements around the Website, and gather demographic information about our user base as a in the aggregate. We and our third party tracking-utility partners use log files on our Service to automatically gather certain information, including but not limited to internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for analytics purposes.  Specifically, we analyze trends, administer the site, track users’ movements around the Website, and gather demographic information about our user base as a in the aggregate.


On this Website, the Company has integrated the component of Google Analytics. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.


The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351.


The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our Website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.


Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of Personal Information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.


The cookie is used to store Personal Information, such as the access time, the location from which the access was made, and the frequency of visits of our Website by the data subject. With each visit to our Internet site, such Personal Information, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These Personal Information are stored by Google in the United States of America. Google may pass these Personal Information collected through the technical procedure to third parties.


The data subject may, as stated above, prevent the setting of cookies through our Website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.


In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this Website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.


Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

Your California Privacy Rights   

This Company is located in California.  As a result, a fair number of visitors to our Website and users of our App may reside in California.


Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes.  This code applies to businesses with 20 or more full or part-time employees.

While the Company does not have 20 or more full or part-time employees, and is not required to comply with this law, as a matter of courtesy to you, we allow you to request and obtain from us once a year, free of charge, certain information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year.  If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to info@brinkapp.co.

Referrals   

If you choose to use our referral service to tell a friend about our Website, App, or Services by email, we will ask for your friend’s email address, and send your friend a one-time email inviting them to visit our Website and inform them of our Services.  We will only stores your friend’s email address for the sole purpose of sending this one-time message and tracking the success of the referral program. Your friend may contact us at info@brinkapp.co to request that we remove this information from our database at any time.


If you submit any Personal Information relating to other people to us or to our service providers in connection with our Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.  


Incorporation into Terms of Service


By using or accessing the Website, App, or the Services, you are accepting the practices described in this Privacy Policy, and you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. This Privacy Policy is incorporated into, and considered a part of, the Company’s Terms of Service.


Opt-Out Policy   


If, at any time after registering, you change your mind about receiving information from us or about the use of information volunteered by you, or if you prefer that we do not share your Personal Information with third parties for marketing purposes, please contact us at info@brinkapp.co.


Changes   


This Privacy Policy may be updated from time to time for any reason, at our sole discretion.  We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on our Website.  You are advised to consult this Privacy Policy regularly for any changes.


Contact Us   


If you have any questions or concerns relating to our use of your Personal Information, please email info@brinkapp.co.  Additionally, you may reach us by postal mail at:


DBK Ventures, Inc. dba Shanidar

226 Amherst Ave

Kensington, CA 94708