Privacy Notice

Effective Date: November 15, 2018

Last Revised: November 15, 2018

At Brightline Dealer Advisors, LLC (in this Privacy Notice, “Brightline,” and the terms “we,” “our,” and “us” refer to Brightline Advisors, LLC), your privacy is incredibly important to us. This Privacy Notice (the “Notice”) describes what information, which includes Personal Information, we collect about you and the users of the Services (collectively, the “Users”), how Brightline will use the information, how the information will be stored, and your rights in relation to the collection of your information when you visit, use, or interact with our website, located at www.brightlinedealeradvisors.com including any subdomains or subpages, (referred to as the “Website” in this Notice), and all associated services offered on or through the Website, (collectively, the Website, and all other services offered on or through the Website shall be referred to herein as the “Services”).

It’s important to know that our Website may contain links to third party sites not controlled by Brightline or covered by this Notice. We recommend that you check the privacy policies of any other sites you visit before providing any information about yourself as their privacy practices may differ from Brightline’s.  If you cannot find the privacy policy of any of these sites via a link from the sites’ homepage, you should contact the site directly for more information.

When you use or access the Website and/or Services, you are accepting the terms and conditions of this Notice, and Brightline will have the right to use your information and Personal Information as described in this Notice. If you do not agree to have your information or Personal Information used in any of the ways described in this Privacy Notice, you must discontinue use of the Website and Services immediately.

Personal Information We Collect
As used in this Notice, “Personal Information” means, “information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.”
We, or a third-party operating on our behalf, collect Personal Information about you when you visit our Website and voluntarily decide to provide Personal Information about yourself.  The Personal Information may include, but is not limited to:

• NAME;
• ADDRESS;
• PHONE NUMBERS (INCLUDING MOBILE);
• EMAIL ADDRESS;
• DATE OF BIRTH; AND
• YOUR PRECISE PHYSICAL LOCATION.

Information We Automatically Collect
When you visit the Website and/or utilize the Services, Brightline automatically collects some information about you and your activities. For example, when you visit the Website, Brightline automatically collects information about your Internet Protocol (“IP”) address, your computer operating system and browser type, the amount of time you spent accessing the Website, language preferences, and the website you were viewing directly before you visited the Website.
The Website, or a third-party service provider, also collects certain information about your usage and activity on the Website by using certain technologies, such as:

• COOKIES. BRIGHTLINE AUTOMATICALLY COLLECTS INFORMATION BY USING “COOKIES.” COOKIES ARE SMALL DATA FILES THAT HAVE UNIQUE IDENTIFIERS AND RESIDE, AMONG OTHER PLACES, ON YOUR COMPUTER, MOBILE DEVICE, AND ON THE WEBSITE. COOKIES HELP BRIGHTLINE IMPROVE THE WEBSITE AND YOUR EXPERIENCE WHEN VISITING THE WEBSITE, BY HELPING WITH TASKS SUCH AS RECOGNIZING YOU AND YOUR BROWSER WHEN YOU VISIT THE WEBSITE, ANALYZING USER BEHAVIOR, AND REMEMBERING YOUR SETTINGS FROM PREVIOUS VISITS.  YOU MAY BE ABLE TO DISABLE COOKIES BY MAKING THE APPROPRIATE SELECTION FROM YOUR BROWSER OPTIONS. HOWEVER, IF YOU CHOOSE TO DISABLE OR DELETE COOKIES, YOU MAY LIMIT THE FUNCTIONALITY BRIGHTLINE CAN PROVIDE WHEN YOU VISIT THE WEBSITE.
• MOBILE DEVICE INFORMATION. WHEN YOU ACCESS THE SERVICES BY USING A MOBILE DEVICE (E.G., A CELL PHONE OR TABLET), BRIGHTLINE MAY COLLECT, STORE, AND PROCESS CERTAIN IDENTIFICATION NUMBERS ASSOCIATED WITH THE DEVICE (E.G., AN IDFA, UNIQUE DEVICE ID, OR GOOGLE AD ID), AND INFORMATION ABOUT THE MOBILE DEVICE MODEL, TYPE, MANUFACTURER, OPERATING SYSTEM, AND PHONE NUMBER.
• WEB BEACONS. BRIGHTLINE MAY COLLECT INFORMATION BY USING WEB BEACONS. WEB BEACONS ARE SMALL, ELECTRONIC IMAGES THAT MAY BE USED ON A WEBSITE OR IN EMAILS. BRIGHTLINE MAY UTILIZE WEB BEACONS TO COUNT VISITS, DELIVER COOKIES, AND UNDERSTAND WEBSITE USAGE.
• DO-NOT-TRACK SIGNALS. WE CURRENTLY DO ACCEPT DO-NOT-TRACK SIGNALS AND DO NOT EMPLOY TECHNOLOGY THAT RECOGNIZES DO-NOT-TRACK SIGNALS FROM YOUR BROWSER.
• LOG DATA. WHEN YOU USE THE WEBSITE, BRIGHTLINE MAY COLLECT INFORMATION CALLED “LOG DATA” OR “LOG INFORMATION.”  IF COLLECTED, THIS INFORMATION WOULD INCLUDE THE BROWSER TYPE AND OPERATING SYSTEM THAT WERE USED TO VISIT THE WEBSITE, THE ASSOCIATED IP ADDRESS FOR THE VISIT, AND THE TIME OF DAY OF THE WEBSITE ACCESS. BRIGHTLINE MAY LOG THIS INFORMATION FOR INTERNAL RECORDKEEPING AND BUSINESS PURPOSES. FOR EXAMPLE, THE LOG INFORMATION IS IMPORTANT FOR AUDIT, SECURITY, QUALITY IMPROVEMENT, AND OTHER INTERNAL BUSINESS PURPOSES.
• INFORMATION ABOUT HOW YOU USE THE SERVICES. WE MAY COLLECT INFORMATION ABOUT YOUR PARTICIPATION AND ACTIONS ON THE WEBSITE. THIS MAY INCLUDE INFORMATION SUCH AS THE PAGES YOU VIEW, HOW YOU BROWSE THE WEBSITE, AND THE VARIOUS FUNCTIONS THAT YOU USE.
• LOCATION DATA. BRIGHTLINE DOES NOT CURRENTLY TRACK OR AUTOMATICALLY COLLECT YOUR PRECISE GEOGRAPHIC LOCATION OR ANY LATITUDE OR LONGITUDE COORDINATES ASSOCIATED WITH YOUR LOCATION. HOWEVER, IT’S IMPORTANT TO NOTE THAT SOME TYPES OF COLLECTED INFORMATION (E.G., YOUR IP ADDRESS) MAY POSSIBLY BE USED TO PROVIDE AN APPROXIMATE LOCATION OF YOUR COMPUTER OR MOBILE DEVICE.  BRIGHTLINE DOES NOT CURRENTLY TAKE ANY STEPS WITH THIS TYPE OF INFORMATION TO IDENTIFY YOUR PRECISE GEOGRAPHIC LOCATION.

How Brightline Uses the Collected Information
We use information (which includes Personal Information) collected on or through the Website for various functions, which may include:

• PROVIDING THE SERVICES TO YOU;
• TO PROVIDE INFORMATION TO YOU ABOUT OUR SERVICES AND/OR NEW PRODUCTS;
• TO ADMINISTER THE WEBSITE AND SERVICES OR TO DIAGNOSE AND RESOLVE TECHNICAL PROBLEMS;
• PROCESSING YOUR REQUEST FOR SERVICES, PRODUCTS, OR INFORMATION;
• IMPROVING OUR SERVICES, CUSTOMER SERVICE, AND/OR PRODUCTS;
• FACILITATING YOUR PARTICIPATION IN ONLINE ACTIVITIES;
• GENERATING, CREATING, AND REVIEWING REPORTS AND OTHER DATA ABOUT THE USERS ON THE WEBSITE AND TO CONDUCT RESEARCH ON THE WEBSITE AND ANY USAGE OR PATTERNS;
• PROVIDE YOU AND OTHER USERS WITH CUSTOMER SUPPORT; AND/OR
• WHERE WE NEED TO COMPLY WITH A LEGAL OR REGULATORY OBLIGATION.

Anonymous or De-identified Information

Brightline may anonymize, aggregate, and/or de-identify collected information, including Personal Information.  As a result, Brightline may use, process, or disclose any such aggregated and/or de-identified information in accordance with applicable law, which does not generally restrict or prohibit the use of aggregated and/or de-identified information. Accordingly, no such use is prohibited by this Privacy Notice, and all such anonymized and de-identified information may be used and disclosed to third-parties without limitation.

How Personal Information is Disclosed

• PERSONAL INFORMATION DISCLOSED TO THIRD-PARTIES
  WE DO NOT DISCLOSE ANY PERSONAL INFORMATION ABOUT YOU TO ANY THIRD-PARTIES EXCEPT AS STATED IN THIS NOTICE, AS OTHERWISE PERMITTED BY LAW, OR AS AUTHORIZED BY YOU.THIRD-PARTIES TO WHOM WE DISCLOSE PERSONAL INFORMATION ARE REQUIRED BY LAW AND CONTRACTUAL UNDERTAKINGS TO KEEP YOUR PERSONAL INFORMATION CONFIDENTIAL AND SECURE AND TO USE AND DISCLOSE IT FOR PURPOSES THAT A REASONABLE PERSON WOULD CONSIDER APPROPRIATE IN THE CIRCUMSTANCES, IN COMPLIANCE WITH ALL APPLICABLE LEGISLATION, WHICH PURPOSES INCLUDE:

• TO PROVIDE THE PRODUCTS AND SERVICES TO YOU;
• TO NOTIFY YOU OR ALLOW OUR AFFILIATED COMPANIES TO NOTIFY YOU OF CERTAIN PRODUCTS OR SERVICES OFFERED BY OUR AFFILIATED COMPANIES;
• TO PROCESS TRANSACTIONS THROUGH DATA PROCESSING SERVICE PROVIDERS; AND
• TO FULFILL MARKETING AGREEMENTS WITH AFFILIATES AND PARTNERS.

Because many of the third-parties (including service providers) we use are located in the United States, including the Brightline affiliates, your Personal Information will be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under U.S. laws.

Personal Information Disclosed to Affiliates

In addition, in the normal course of providing the Services, Personal Information may be shared within Brightline and with its affiliates (which includes the parents, subsidiaries, and affiliates of Brightline) in order to provide the Services, perform analysis and research, for marketing purposes, for the improvement of the Services, to perform system administration, and/or crime prevention or detection.

Business Transactions

Your Personal Information may be disclosed in connection with any Brightline transaction, such as a merger, sale of all or a substantial portion of RTDI’s assets or shares (including a change of control or acquisition of all or a portion of our business), reorganization, or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings.

Applicable Law

In our discretion, Brightline may disclose Personal Information to, (i) enforce Brightline’s policies and procedures, including the investigation of any potential violation, (ii) satisfy applicable law, legal process, regulation, subpoena and/or court order, or other government request,  (iii) investigate any claim or allegations and defend itself against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of Brightline, the Users, or any member of the public, as required or permitted by applicable law and (v) detect, prevent or otherwise address criminal or potentially criminal behavior, or security or technical issues.

Advertising

In accordance with applicable law, Brightline, or a third-party operating on Brightline’s behalf, may use the information (which includes Personal Information) collected about you and other Users to advertise to you and/or customize the advertisements you see. This information may be combined and linked with data from other sources.

Security of Your Personal Information

We restrict access to the Personal Information obtained from the Website to only those employees, agents and contractors who need it to do their jobs and provide the Services. In addition, we maintain administrative, technical, and physical safeguards designed to protect your Personal Information.  Among the safeguards are the encryption of communications and information via Secure Socket Layer (SSL) encryption technology, access controls, separation of duties, and similar security protocols. However, due to the nature of the Internet and related technology, we cannot guarantee the security of Personal Information, and Brightline expressly disclaims any such obligation.

Access to Your Personal Information

You have the right to access your Personal Information and request rectification of any Personal Information in Brightline’s files that may be obsolete, incomplete, or incorrect. However, to help secure your Personal Information, Brightline does not provide online access to its Users to view or amend Personal Information in its database. If you have any questions about the Personal Information Brightline has stored about you, or you would like to correct, update, or amend any such Personal Information, please contact Brightline as provided below.

Information Retention

Brightline will, in accordance with applicable law, store your information and Personal Information for as long as necessary to provide you the Services. Please contact Brightline to have your information and/or Personal Information removed from our files. We will respond to any such requests in accordance with our standard practices, but in any case, it may take up to thirty (30) days to complete your request(s).  We will only retain your information or Personal Information after receiving a request to remove your information or Personal Information for longer than that provided above in order to satisfying any legal, accounting, or reporting requirements.

Brightline‘s Policy Towards Children

The Service and Website are not directed towards any individual or person who is under 18 years of age. Brightline does not knowingly or intentionally collect Personal Information from persons under 18. If you are a parent or guardian, and you learn that your child or minor under the age of 18 has provided Brightline with Personal Information, please contact Brightline immediately. If we become aware that we have collected Personal Information from a minor without verification of parental consent, then we will immediately remove that information from our servers.

California Privacy Rights

California’s Shine the Light law provides California residents with the right to receive disclosures about any sharing of their personal information with other companies.

If you are a California resident and you provided your personal information to Brightline, then, once each calendar year, you may submit a written request for information about the information we shared, if any, with other companies for their use in direct marketing. To submit your written request, please contact Brightline at the address or email address provided below.

Within 30 days of receiving your request, Brightline will send you a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties.

Brightline reserves the right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this Notice.

Changes to this Notice

This Notice is effective November 15, 2018. We reserve the right to alter this Notice at any time in our sole discretion. Any change to this Notice will be posted on the Website in a timely manner.

Notice to You

If we need to provide you with a notification or information about the Services, whether for legal or other business-related purposes, then we will send you such notifications and information via the email address we have for you.

Contacting Us

If you have any questions or concerns relating to the processing or use of information or Personal Information described in this Privacy Notice, you may contact us at:

Brightline Dealer Advisors, LLC

13455 Noel Road, Suite 2300

Dallas, Texas 75240

Email: RTDA@risktheory.com