BROAD PROJECT LLC IS CONCERNED ABOUT PRIVACY ISSUES AND WANTS YOU TO BE FAMILIAR WITH HOW WE COLLECT, USE, AND DISCLOSE YOUR INFORMATION.
This privacy policy (this Policy) applies to Broad Project LLC, a California limited liability company (hereinafter referred to as Broad Project, "we", "us", or "our"). This Policy describes our practices in connection with information that we collect through websites operated by us from which you may be accessing this Policy, including https://www.broadproject.com/ (the "Websites"), through our social media pages that we control from which you may be accessing this Policy (collectively, our “Social Media Pages”), as well as through HTML-formatted email messages that we send to you that link to this Policy (collectively, including the Websites and our Social Media Pages, the Services). The Services are currently used for marketing and portfolio display purposes.
Please read this Policy carefully. By using the Services, you consent to our collection, processing, retention, use, and disclosure of your Personal Information (defined below) as described in this Policy. Except as set forth in this Policy, your Personal Information will not be used for any other purpose without your consent. You may withdraw your consent to our processing of your Personal Information at any time, subject to our rights and obligations under applicable law. However, withdrawing consent may result in your inability to continue using the Services or some of their features.
DEFINITIONS
As used in this Policy, the terms below shall have the following meanings:
Sell has the meaning set forth in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the CCPA).
Share means sharing Personal Information with third parties for cross-context behavioral advertising, as that term is defined under the CCPA.
Access Request means a verifiable consumer request to know or obtain a copy of the Personal Information that we have collected, used, disclosed, or shared about you, consistent with the rights provided under the CCPA.
Deletion Request means a verifiable consumer request to delete Personal Information that we have collected from you, subject to the exceptions and limitations provided under the CCPA.
Data Portability Request means a verifiable consumer request to obtain a copy of your Personal Information in a portable and readily usable format, consistent with the rights provided under the CCPA.
Personal Data has the meaning given in the EU General Data Protection Regulation (GDPR) and may differ from Personal Information as defined in this Policy.
PERSONAL INFORMATION WE MAY COLLECT
Personal Information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you as a particular consumer or household, whether on its own or when combined with other information. We do not currently collect Personal Information through the Services. However, we may collect Personal Information from you offline or from third-party sources (as described below), and in the future, if we activate online features, we may collect Personal Information through the Services, including but not limited to your:
In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or on other information we collect.
If and when we add e-commerce features to the Services, we may use a third-party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information may be collected by such third party and not by us and will be subject to the third party’s privacy policy, rather than this Policy. We have no control over, and are not responsible for, that third party’s collection, use and disclosure of your Personal Information.
If you submit any Personal Information relating to other people to us or to our third-party service providers in connection with the Services, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy.
HOW WE MAY COLLECT PERSONAL INFORMATION
We and our service providers may collect Personal Information in a variety of ways, including:
HOW WE MAY USE PERSONAL INFORMATION
We may use your Personal Information:
HOW PERSONAL INFORMATION MAY BE DISCLOSED
Your Personal Information may be disclosed for the following business purposes:
To our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services.
To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
OTHER INFORMATION
Other Information is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
Browser and device information, including device IDs, advertising IDs, and other persistent identifiers, such as your IP address. Your IP address is a number that is automatically assigned to the computer that you are using by your internet service provider (ISP).
Information collected through cookies, pixel tags and other technologies, such as the actions taken within and outside of the Websites and the date and time of your use of the Websites.
Demographic information such as your gender or city and other information voluntarily provided by you.
Aggregated information.
HOW WE MAY COLLECT OTHER INFORMATION
We and our third-party service providers may collect Other Information in a variety of ways, including:
Through your browser or device. Certain information is collected by most browsers or automatically through your device, such as your media access control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
Using cookies. Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, and other anonymous traffic data. We and our service providers may use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience while using the Services. We may also use cookies in online advertising to track responses to our advertisements.
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 to be given the choice of declining or accepting the transfer to your computer of a cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.
Using pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear gifs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
Through your IP address. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We may use IP addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
From you. Information such as your preferred means of communication is collected when you voluntarily provide it. Unless combined with Personal Information, it does not personally identify you.
By aggregating information. Aggregated Personal Information does not personally identify you.
HOW WE MAY USE AND DISCLOSE OTHER INFORMATION
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.
If under applicable law we are required to treat Other Information as Personal Information, then we may collect, use, or disclose Other Information in the same manner as Personal Information as described in this Policy.
In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information for so long as it is combined.
THIRD-PARTY SERVICES
This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. We disclaim all liability for any third-party acts, omissions, or policies, and you should review the privacy policies of such third parties carefully. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Twitter, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.
Specifically, we use the following third-party service providers in order to provide the Services to you:
Domain:
SquareSpace. Our website is hosted on Squarespace, Inc. Squarespace provides us with the online platform that allows us to market, advertise and sell our Services to you. Your data may be stored through Squarespace’s data storage, databases, and the general Squarespace application.
Hosting:
DigitalOcean. Our website is hosted on DigitalOcean, LLC, which provides secure cloud infrastructure. DigitalOcean may collect technical information, such as IP addresses, to maintain security and improve services. DigitalOcean treats data in compliance with their security policies.
Analytics:
Google Analytics. Our website uses Google Analytics, a web analysis service from Google Inc. (Google). Google uses cookies, which are text files placed on your computer, to analyze how users interact with our site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to evaluate your use of the website, compile reports on website activity, and provide other services related to website activity and internet usage. You may refuse the use of cookies by selecting the appropriate settings on your browser. For more information on how Google handles your data, please refer to the Google Privacy Policy here: https://policies.google.com/privacy
Google Tag Manager. We use Google Tag Manager to manage and deploy marketing and analytics tags on our website. For more information on how Google handles your data, please refer to the Google Privacy Policy here: https://policies.google.com/privacy
Meta Pixel. We use Meta Pixel, a web analytics tool provided by Meta Platforms, Inc. The pixel tracks how you use our site, including pages visited and actions taken. This data is shared with Meta. You can opt-out of this tracking by updating your Meta ad preferences here: https://www.facebook.com/adpreferences/ad_settings
We require our third-party service providers to implement appropriate technical and organizational measures to protect Personal Information and to process such information only as necessary to provide services to us.
SECURITY
We implement and maintain commercially reasonable organizational, technical, and administrative safeguards, including encryption, access controls, and regular security assessments to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the Contacting Us section below.
CHOICES AND ACCESS
Your choices regarding our use of your Personal Information:
If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at studio@broadproject.com and include the word security in the subject line.
How you can access, change or suppress your Personal Information:
If you would like to review, correct, update, suppress, or delete the Personal Information that you have provided to us, you may contact us by email at studio@broadproject.com or write to the following address:
Broad Project LLC
2121 Avenue of the Stars, Suite 800
Los Angeles, CA 90067
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have it suppressed from our database, or otherwise let us know what limitations you would like to put on our use of it. For your protection, we may only implement requests with respect to the Personal Information associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes or to complete any transactions that you began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
We do not currently recognize Do Not Track signals, but we honor browser-based opt-out signals that are legally required under the CCPA, including the Global Privacy Control.
EU USERS’ RIGHTS
The General Data Protection Regulation (GDPR) provides users located in the EU under its protection certain rights with respect to their Personal Data collected by us on the Websites. Accordingly, we recognize and will comply with the GDPR and those rights, except as limited by applicable law. The rights under the GDPR include:
Right of Access: This includes the right to obtain from us your Personal Data and whether it is being processed, along with the purposes of the processing; categories of Personal Data concerned; recipients to whom your Personal Data has been disclosed; the period for which your Personal Data is being stored; and the right to lodge a complaint.
Right of Rectification: This includes the right to correct inaccurate Personal Data collected or stored by us.
Right of Erasure: This includes the right to have your Personal Data deleted. However, if applicable law requires us to comply with your request to delete information, fulfilment of your request may prevent you from using our Services and may result in closing your account.
Right to Restriction of Processing: This includes the right to request restriction of how and why your Personal Data is used or processed by us.
Right to Data Portability: This includes the right to receive your Personal Data in a structured, readable format and the right to have your Personal Data transferred.
Right to Object: This includes the right to object to us processing your Personal Data for reasons such as direct marketing purposes and for scientific or historical research or statistical purposes.
Right to not be Subject to Automated Decision-Making: This includes the right to not be subject to a decision based solely on automated processing, including profiling, that could have a legal, or similarly significant, effect on you from being made solely based on automated processes.
Under the GDPR, the lawful basis for us processing your Personal Data for the uses described herein will typically be because you have provided your consent; it is necessary for our contractual relationship; the processing is required for us to comply with legal obligations; or the processing is in our legitimate interest in providing you with the Services.
CALIFORNIA USERS’ RIGHTS
Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), if you are a resident of California you have the following rights with respect to your Personal Information:
Right to Know and Data Portability Requests: You have the right to request that we disclose what Personal Information of yours we collect, use, disclose, Share and Sell (the “Right to Know”), including the specific pieces of Personal Information we have collected about you (an “Access Request” and, where applicable, a “Data Portability Request”) over the past twelve (12) months.
Right to Delete and Right to Correct: You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions and limitations (the “Right to Delete”). You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the “Right to Correct”). We may require you to provide documentation, if needed, to confirm your identity prior to deleting or correcting your Personal Information.
Right to Limit Use and Disclosure of Sensitive Personal Information: You have a right to ask businesses that use or disclose your Sensitive Personal Information to limit those actions to just the CCPA’s Permitted Sensitive Personal Information Purposes (the “Right to Limit”).
Right to Opt-Out of the Sale or Sharing of Personal Information: Under the CCPA, disclosure of your Personal Information to third parties in exchange for monetary or other consideration is considered to be a sale of personal information. We do not Sell your Personal Information. To the extent that our use of third-party tracking technologies (such as Meta Pixel) constitutes sharing of Personal Information for cross-context behavioral advertising under the CCPA, you have the right to opt out of such sharing.
Right of Children to Opt-In to the Sale or Sharing of Personal Information: The CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under sixteen (16) years old without first obtaining consent from consumers who are between thirteen (13) and fifteen (15) years old or the consumer’s parent or guardian for consumers under age thirteen (13) (the “Right to Opt-In”). We do not knowingly Sell or Share the personal information of minors under sixteen (16) years of age without affirmative authorization.
Right to Non-Discrimination: You have the right to not be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.
California “Shine the Light” Rights: Individual consumers who reside in California and have provided us with their Personal Information may request information about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. The information we provide will describe our general practices in the prior calendar year and will not be specific to you. Your request must indicate that you are a California resident and include your current California address. Please submit a written request to us using the email or address in accordance with the “Contacting Us” section below. Please note that we are required to respond to only one request per California customer each year.
Notice at Collection: The tables below describe the categories of information we collect, disclose for a business purpose and Share or Sell, as well as the third parties to whom such information is disclosed, Shared or Sold. Please note, in addition to the recipients identified below, we may disclose any of the categories of information we collect listed in the charts below with government entities, as may be needed to comply with law or prevent illegal activity. We do not sell your Personal Information. As discussed above in the Policy, we may use cookies and similar tracking technologies for purposes of targeted advertising. For details regarding how we use such information, please see the above How We May Use Personal Information section of this Policy. For an explanation regarding how long we retain such information, please refer to the Retention Period section of this Policy.
PERSONAL INFORMATION: COLLECTION, SHARING, SELLING AND DISCLOSURE
The chart below identifies which categories of Personal Information we collected from our consumers within the last twelve (12) months. We may disclose the Personal Information we collect to third parties for the business purposes described in the HOW PERSONAL INFORMATION MAY BE DISCLOSED section above.
| Category of Personal Information | Personal Information Collected? | Shared in the Past 12 Months? | Categories of Third Parties to Whom Shared | Categories of Third Parties to Whom We Disclosed for a Business Purpose |
|---|---|---|---|---|
| Individual Identifiers | NO | NO | N/A | N/A |
| Categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | NO | NO | N/A | N/A |
| Characteristics of protected classifications under California or federal law | NO | NO | N/A | N/A |
| Commercial information | NO | NO | N/A | N/A |
| Biometric information | NO | NO | N/A | N/A |
| Internet or other similar network activity | NO | NO | N/A | N/A |
| Geolocation data | NO | NO | N/A | N/A |
| Sensory data, including audio, electronic, visual, thermal, olfactory, or similar information | NO | NO | N/A | N/A |
| Professional or employment-related information | NO | NO | N/A | N/A |
| Non-public education information | NO | NO | N/A | N/A |
| Inferences drawn from other Personal Information | NO | NO | N/A | N/A |
SENSITIVE PERSONAL INFORMATION:
COLLECTION, SHARING, SELLING AND DISCLOSURE
*Sensitive Personal Information”*is a subtype of Personal Information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive when we collect or use it to infer characteristics about a consumer.
We do not intentionally collect Sensitive Personal Information and ask that you do not provide any such Sensitive Personal Information to us on or through the Services or otherwise. If you provide such information, we will delete it or limit its use to CCPA-permitted purposes unless you provide explicit consent for broader use. We do not sell your Sensitive Personal Information.
The chart below identifies which Sensitive Personal Information categories, if any, we have collected from consumers to infer characteristics about them in the last twelve (12) months.
| Category of Sensitive Personal Information | Collected? | Shared in the Past 12 Months? | Categories of Third Parties to Whom Shared | Categories of Third Parties to Whom We Disclosed for a Business Purpose |
|---|---|---|---|---|
| Social Security number, driver’s license, state ID card, or passport number | NO | NO | N/A | N/A |
| Account Log-in and Password | NO | NO | N/A | N/A |
| Financial Account, Debit Card, Credit Card Number and account access information. | NO | NO | N/A | N/A |
| Precise geolocation | NO | NO | N/A | N/A |
| Racial or ethnic origin, religious or philosophical beliefs or union membership | NO | NO | N/A | N/A |
| Citizenship or immigration status | NO | NO | N/A | N/A |
| Contents of mail, email, or text messages not directed to us | NO | NO | N/A | N/A |
| Genetic data | NO | NO | N/A | N/A |
| Unique identifying biometric information | NO | NO | N/A | N/A |
| Health information collected and analyzed | NO | NO | N/A | N/A |
| Sex life or sexual orientation information | NO | NO | N/A | N/A |
EXERCISING YOUR RIGHTS UNDER THE CCPA
To exercise your rights under the CCPA – or have an authorized agent exercise your rights under the CCPA on your behalf – please submit a request by contacting us at studio@broadproject.com with the subject CCPA Consumer Request. Broad Project will verify this request by ensuring that it originated from the registered email address and may require additional information to complete verification. We reserve our right to not grant a consumer request if we cannot verify that the person making the request is the person about whom we have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of Personal Information twice within a twelve (12) month period. Any Personal Information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification. We will verify your identity using reasonable methods appropriate to the type of request. For Access Requests, we require two pieces of identification. For Deletion Requests, we may require additional documentation.
RETENTION PERIOD
We will retain your Personal Information for only as long as reasonably necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. Retention periods may vary depending on the type of Personal Information, the context in which it was collected, and applicable legal, regulatory, tax, or business requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and the applicable legal requirements.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of thirteen (13). Because we do not actively collect Personal Information through the Services at this time, we do not anticipate receiving Personal Information from minors. We do not knowingly Sell or Share the Personal Information of consumers under the age of sixteen (16).
If we learn that we have inadvertently received Personal Information from a child under thirteen (13), we will attempt to delete that information from our systems promptly.
If you are a parent or guardian of a child under thirteen (13) years of age and you believe your child has provided us with Personal Information, please contact us at studio@broadproject.com and we will attempt to delete the information from our system.
DATA BREACH NOTIFICATION
In the event of a data breach that affects your Personal Information, we will provide notification as required by applicable law, including notification to you and relevant authorities within the timeframes specified by law.
CROSS-BORDER TRANSFER
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country. For international transfers, we implement appropriate safeguards as required by applicable law.
UPDATES TO THIS PRIVACY POLICY
We may change this Policy from time to time. The Last Updated legend at the top of this page indicates when this Policy was last revised. Any changes to this Policy will become effective when we post the revised privacy policy on the Services. Your use of the Services following these changes means that you accept the revised Policy.
DISCLAIMER
This Policy is designed to comply with applicable privacy laws as of the last updated date. Privacy laws continue to evolve, and we may need to modify this Policy to maintain compliance. You should review this Policy periodically for updates.
CONTACTING US
If you have any questions about this Policy, please contact us by email at studio@broadproject.com or at the following address:
Broad Project LLC
2121 Avenue of the Stars, Suite 800
Los Angeles, CA 90067
Because email communications are not always secure, please do not include sensitive information in your emails to us.